The Union has lodged an official complaint with the Information Commissioner over the FCA’s refusal to answer questions about Lloyds Banking Group’s implementation of overdraft charges for customers and staff earlier this year.

In a letter to Mr Andrew Bailey, dated 20th December 2017, we asked him to confirm that all customers affected by the new charges, which would have included many Lloyds Banking Group staff and retired staff, had received the appropriate legal communications notifying them of the new charges. In one of our letters to Mr. Bailey we said:

“I apologise for the delay in replying to your letter but we have been consulting our legal advisers regarding the information we can share with the FCA, given that it has been provided to the Union on a confidential basis. In response on to my question of 1st November you say “You are correct to assume that we were aware of this specific rectification programme and the remedy to fix the underlying problem was implemented in November 2016. We understand the problem has been fixed…….”. If the problem has been fixed why was the Bank still maintaining in Q1 2017 that its number one problem was “its inability to process and maintain accurate customer address data”. I can confirm that the Bank started a rectification project called ‘Com21’ a few months ago, which will involve writing to millions of customers over the next 18 months.

I should be grateful if you would confirm:

  • That the 1.5 million customers the Bank had flagged up as ‘Gone Away’ (out of total 3.5 million ‘Gone Away’ customers) but who were subsequently found to be living at the address on the Bank’s system received communications on the new overdraft charges.
  • The 300,000 customers with blank addresses received the communication on overdraft charges.
  • The 150,000 customers with incorrect postcodes received the communication on overdraft charges.
  • That those customers with one record where the name and/or address is different received the communication on overdraft charges.

Given what you said in your previous letter, if the problem of incorrect home addresses has not been fixed then that would have affected the communication to customers on the changes to overdraft charges. In the light of this new information, the question is what is the FCA going to do to fulfil its statutory operational objective of: “securing the appropriate degree of protection for consumers”.

Our legal adviser has confirmed that your statutory operational objectives are legally enforceable”.

Despite requests from the Union, Mr Bailey has refused to answer the questions we have asked or provide assurances that all customers were notified properly about the bank charges.

BTU will also be writing to request that the FCA publish all correspondence with LBG on this issue including letters, emails and notes of all telephone conversations.


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