12 Apr 2018 Speech
Seminar by Derville Rowland, Director General, Financial Conduct, Galway Mayo Institute of Technology, 12 April 2018
I am delighted to be here with you at the Galway Mayo Institute of Technology. I want to talk to you today about what the Central Bank of Ireland is doing to protect consumers. I will explain, first of all, the scope of our regulatory and supervisory work, particularly our consumer protection work, and then detail why we are now increasingly requiring financial services firms to transform their culture in order to better protect consumers.
The Watchful Eye
I was very struck by research conducted more than a decade ago which considered the effect of an image of a pair of eyes on contributions to an honesty box used to collect money for drinks in a university coffee room. The research found that people contributed nearly three times as much for their drinks when they saw the image of eyes over the box compared with a control image of a bunch of flowers. The conclusion was that, when people are conscious of being watched and mindful of the possible reputational consequences, they behave in ways that increase their contribution to a public good1.
I like to think of that “watchful eye’’ as a metaphor for how regulators can help contribute to the public good by rebuilding trust in the financial system which was so badly shattered following the financial crisis, particularly here in Ireland. But of course, we have to do more than just watch, we need to act on what we see.
Financial regulation – what we do
The Central Bank of Ireland’s mission is to safeguard stability and protect consumers.
Our work in financial regulation spans five key areas – conduct regulation, anti-money laundering, infrastructure, micro-prudential regulation and macro-prudential regulation.
Conduct regulation focuses on how firms and the people who run them operate and behave towards their customers. It also focuses on how that behaviour affects trust and confidence in the financial system and the fair, orderly and effective functioning of financial markets.
We monitor financial institutions’ compliance with their obligations to prevent money laundering and counter terrorist financing so that the proceeds of crime and terrorism don’t find their way in to the financial system.
We oversee the financial services infrastructure and promote the safe and efficient operation of payment and securities settlement systems.
Microprudential regulation deals with prudent financial standards for individual institutions. It seeks to ensure that firms have sustainable, capital generating business models; are governed and controlled appropriately with clear and embedded risk appetites; have sufficient financial resources; and are resolvable in the event of failure without recourse to the taxpayer.
Macroprudential regulation seeks to promote financial stability by strengthening the resilience of the banking system so that it can withstand adverse movements in credit and property prices and other macroeconomic shocks.
Scale of the Central Bank’s activity – we regulate 10,000 firms
To give you an idea of the scale of our operations, we regulate about 10,000 firms providing financial services in Ireland and overseas. These span a multitude of sectors including investment and insurance brokers, bureaux de change, credit institutions, credit unions, credit servicing firms, debt management firms, payment and electronic money institutions, funds and funds service providers, insurance companies, investment firms, moneylenders, retail credit and home reversion firms and securities market operators.
In order to supervise the financial services industry, we must also understand the drivers in that industry, the business models adopted by those we supervise, and the risks to which they and their clients are exposed. We must also foster an effective supervisory relationship to allow us to assess how the rules are working in practice and whether amendments are required to deliver a more effective regulatory regime.
It is essential that the laws and regulations we use are well-crafted, consistently drafted and designed to be effective and enforceable.
By its nature, much of what we do happens behind the scenes and in private. As regulators, we are granted access to confidential commercial information in order to carry out our supervisory work, but we are legally restricted from disclosing or sharing the confidential information that the firms supply for this purpose.
Finally, we must deploy enforcement measures, where appropriate, to investigate why a breach has occurred, how it can be rectified and how to prevent it reoccurring in the future. This may involve the imposition of any one or a combination of sanctions and other remedies.
Recognising that, of necessity, much of our work is done in private and to promote transparency where we can, we strongly support detailed enforcement outcomes being published. To date, all our enforcement outcomes are publically available for all to see.
The Irish Consumer Protection Landscape
There are a number of agencies charged with the protection of consumers of financial products in Ireland.
The Central Bank is a systemic regulator. We aim to secure financial stability which is a major component in protecting consumers. We also set statutory codes of conduct for financial services firms, such as codes on how products should be sold, the information that should be provided and how complaints should be dealt with.
The role of the Competition and Consumer Protection Commission includes the provision of personal finance information and education, including a web helpline and comparisons of financial products.
The Financial Services and Pensions Ombudsman assesses the complaints of individual consumers against their financial services providers and can direct redress where he finds against a firm.
Of course, consumers’ interactions with financial services providers are also governed by contract law so that a consumer can also take action through the courts against a financial services provider.
We seek to incorporate best international practice in to our regulatory and supervisory activities and to influence EU and international initiatives by sharing our expertise and perspectives with other regulators. For example, we work closely with the three Supervisory Authorities – the European Banking Authority (EBA), the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA).
We also have a particular interest in learning from and influencing leading edge consumer protection measures. We were one of the founding members of FinCoNet, an international organisation of supervisory authorities with responsibility for financial consumer protection. We chaired the EBA Standing Committee on Consumer Protection and Financial Innovation for two years. We participate on the OECD Task Force on Consumer Protection, where our work included influencing the development of the ten high-level international principles of financial consumer protection, which were endorsed by the G20 Finance Ministers and Central Bank Governors in 2011.
These non-binding principles include that financial consumer protection should be an integral part of the legal, regulatory and supervisory framework; that consumers should be treated equitably, honestly and fairly at all stages of their relationship with financial services providers; and that consumers should be given key information about the fundamental benefits, risks and terms of the products they buy.
Last year, the Central Bank split its Financial Regulation Pillar in to two – the Financial Conduct Pillar, which I lead, and the Prudential Regulation Pillar. The Financial Conduct pillar is responsible for the proper and effective regulation of financial services providers and markets with the aim of ensuring that the best interests of customers are protected in line with the high standards set out in the European and domestic regulatory frameworks. We focus on consumer and investor protection and the orderly functioning of financial markets.
Our vision is for a financial services system underpinned by a strong culture of compliance and trust-worthiness, with firms and the people working in those firms acting in the best interests of their customers. Where we see outcomes, which fall below these standards, we will act decisively, making full use of the powers the Oireachtas has given us, through rigorous supervision supported by a credible threat of enforcement, including redress where customer detriment has occurred.
The Importance of Financial Services
Many of you here today are working in the financial services sector, or may be interested in working in the financial services sector in the future. The sector makes a valuable contribution employing about 106,000 people, contributing €16.8 billion to the economy and paying 28 per cent of net corporation tax or €2.1 billion.2
Financial services are a necessary part of all our daily lives whether we are paying for goods and services by cash, credit or debit card; transferring money online or offline; borrowing from a moneylender; taking out a mortgage; securing a farm loan, or saving for retirement and investing. Financial products bring benefits. But they can also bring risks or detriment if the right product is not sold to a consumer in the right way or if the institution is unable to meet its financial obligations to the consumer.
When I think about consumer protection, I think about making sure that financial organisations put their customers’ interest first and sell them suitable products. I think about how firms should deal with first-time home buyers, who are making one of the biggest financial decisions of their lives. I think about how they should deal with customers investing lump sums on which they may have to rely well in to their old age. I think about how they should deal with vulnerable customers who may not have easy access to credit or ones whose mortgages are in arrears. And I think of how they should handle complaints and errors when things go wrong.
In short, I want firms to treat their customers with dignity and respect, and to support them in making good financial decisions.
Behavioural Economics – uncovering marketing tricks
Some of the biggest financial decisions consumers ever make happen only rarely such as when they take out a mortgage or invest in a pension. The consumers find themselves dealing with institutions and individuals who have far greater knowledge and experience of financial products and markets than they do.
The Central Bank is very conscious of this information imbalance between consumers and financial services providers. We are therefore increasingly using insights from behavioural economics to help us identify how we can strengthen regulatory requirements to ensure firms help consumers make better choices.
Many of you will have heard of Professor Richard Thaler who won the Nobel Prize for economics last year for his work exploring how human psychology shapes economic decisions – a discipline known as behavioural economics.
Thaler’s insights have helped people to recognise marketing tricks, which may prompt consumers to make the wrong choices. His work has also looked at how to “nudge” people into doing more long-term planning, such as saving for a pension.
At the Central Bank we seek to inform ourselves – both through our own research and by reviewing the work of other leaders in the field – about ways in which firms knowingly take advantage of consumer behaviours and biases. The aim is to prevent so-called “evil nudges’’ which prompt consumers to make poor choices.
We are also undertaking research focussing on the connection between household financial decisions and behavioural factors. This research will show how behavioural traits correlate with significant mortgage decisions such as the decision to refinance one’s mortgage, the decision to switch mortgage provider or indeed the decision about the type of mortgage to take on when purchasing a home.
As we learn more about what drives their behaviour, we will seek to strengthen the regulatory protections for consumers to ensure that firms do not unfairly exploit them. We want financial institutions to nudge their customers to make the right decisions, rather than the wrong ones.
For example, research has shown that “high cost loan” warnings reduce the chances that consumers opt for loans with high APRs. The Central Bank of Ireland requires such warnings to be provided for moneylender loans.
Consumer Protection Code
One of the key ways the Central Bank works to achieve good outcomes for consumers is through our codes, particularly the Consumer Protection Code. First launched in 2006, the Code was a first in terms of how it prescribed products should be sold, the information that should be provided to consumers, how complaints should be dealt with and how customers should be treated. The Code provides among other things that regulated firms must:
- Act honestly, fairly and professionally in the best interests of their customers and the integrity of the market
- Act with due skill, care and diligence in the best interests of customers
- Not recklessly, negligently or deliberately mislead a customer as to the advantages or disadvantages of any product or service
- Make full disclosure of all relevant material information, including all charges, in a way that seeks to inform the customer
- Seek to avoid conflicts of interest
- Correct errors and handle complaints speedily, efficiently and fairly.
Betting on a horse
We are constantly reviewing and updating our codes both to keep pace with new European legislation and to ensure that the codes continue to address consumer concerns.
One of the ways we do this is through thematic inspections. As part of our investor protection work, we conducted an inspection of Contracts for Difference, complex financial products, which enable investors to speculate on the short-term price movements of an underlying reference asset.
The inspection found that 75% of retail CFD clients who invested in CFDs during 2013 and 2014 made a loss, of which the average loss was €6,900. We found retail clients generally were not sufficiently aware of the high risk and complex nature of the product.
A recent follow-up review by the Central Bank of a sample of the largest CFD providers in Ireland found that in the two-year period up to 31 December 2016, 74% of retail clients lost money with an average loss of €2,700.
I am a member of the European Supervisory and Markets Authority (ESMA). One of the issues ESMA has been keeping a watchful eye on are CFDs and binary options. We have concluded that there exists a significant investor protection concern in relation to CFDs and binary options offered to retail investors. Last month, we announced a prohibition on the marketing, distribution or sale of binary options to retail investors and a restriction intended to cap the amount retail investors can lose on CFDs.
The Central Bank has also warned investors against binary options and welcomed the decision by ESMA to prohibit the sale of binary options. We also welcomed the temporary measures imposed on CFDs by ESMA, which include a limitation on leverage and the introduction of measures to ensure retail investors cannot lose more money than they put in.
Binary options almost always lead to the retail investor losing and, in my personal view, they are no more an investment than betting on a horse and have no place in the investment plans of retail investors.
Conflicts of Interest – Salesperson’s or Consumer’s interests being served?
Another way the Central Bank keeps in touch with the concerns of consumers is by conducting consumer research. For example, last year we conducted research, which found that 61% of respondents agreed with a statement that brokers primarily advise based on what products will earn them the most commission.
The manner by which financial institutions pay intermediaries who sell their products influences the behaviour of those intermediaries. It is imperative, therefore, to design remuneration arrangements to encourage responsible business conduct, fair treatment of consumers and to avoid conflicts of interest.
That is why the Central Bank is proposing that it is unacceptable to offer inducements linked to targets that do not consider the consumer’s best interests, such as volume, profit or business retention targets.
Protecting Consumers in Mortgage Arrears
Everybody in the room is conscious of the legacy of the financial crisis, which has left many people shouldering mortgages they can no longer afford. The Central Bank’s main consumer focused policy instrument has been the Code of Conduct on Mortgage Arrears (CCMA), which came into force in February 2009 and was later revised. The CCMA is intended to ensure fair and transparent treatment of financially-distressed borrowers and to ensure that each mortgage arrears case is considered on its own merits.
Given the concerns being raised about the sale of loan books to unregulated entities – or “vulture funds’’ as they are often described – the Minister for Finance has requested the Central Bank to carry out a review of the CCMA to ensure it remains as effective as possible.
As far back as 2011, we highlighted the implications for consumers arising from the sale of loans to unregulated loan owners. We advocated for the preservation of the protections afforded to borrowers under the regulatory framework. Following a public consultation by the Department of Finance, the Central Bank worked with the Department to develop the Consumer Protection (Regulation of Credit Servicing Firms) Act, which came into effect in July 2015. The Act seeks to ensure that the consumer protections travel with the loans if they are sold to new owners.
The approach provides important protections for borrowers whose loans are sold to unregulated third parties with a view to maintaining the regulatory protections they had prior to the sale. We are now also working on informing the Department of Finance in its work on developing further proposals to protect consumers when their loans are sold to unregulated entities.
Protecting vulnerable customers from moneylenders
We also seek to strike a balance between enabling the 350,000 consumers who use the services of licensed moneylenders to continue to have access to credit, while protecting them from becoming over-indebted.
Just last month, we proposed enhancements to the Consumer Protection Code for Licensed Moneylenders including putting in place a specific limit on how much of a consumer’s earnings can be devoted to paying off high-cost moneylending agreements.
Since assuming responsibility for the regulation of the moneylending sector in 2003, the Central Bank has not permitted any increase to the maximum APR charged within the sector. The APRs charged have remained largely unchanged since 2003.
In that regard, we stand in marked contrast to the UK and the United States. The Central Bank, through the licensing regime, has not permitted practices such as payday moneylending, where APRs charged are typically much higher (up to 1,500% APR in the UK), to enter the Irish moneylender market.
Helping consumers help themselves
In 2015, the Central Bank published research on the savings that could be made from switching mortgages. Based on the analysis of over half a million mortgages, we found that up to 21 per cent of loans could save money by switching mortgage.
Of course, not everyone can switch for a variety of reasons, such as being in mortgage arrears. But we found that, for those mortgages which can save money by switching, approximately 16,000 will save over €1,000 in the first 12 months, and about 27,000 switchers have the potential to save in excess of €10,000 over the lifetime of the loan.
That is why we are now planning to include enhanced mortgage switching measures in the Consumer Protection Code. The measures will help consumers by requiring lenders to inform them of other available options that could save them money and requiring regulated entities to provide them with standardised switching information and follow a time-bound switching process.
We recognise that the costs of mortgage switching such as a new valuation and re-registering of a charge over a property, can act as a disincentive to consumers achieving the benefits of switching; not all consumers who would benefit can actually make the switch. But the measures we plan will help to keep competitive pressure on banks to provide value for money mortgage products and help to set standards in how banks treat their mortgage customers.
It is important also for consumers to keep an eye out for advice and information that may help them save money in the long-term. In that regard, I would point to the Competition and Consumer Protection Commission website, which contains helpful information for consumers.
As the economy continues to recover, the Central Bank has been playing its part both to protect the financial system and consumers. A recent example is the introduction of the macro-prudential mortgage lending rules aimed at reducing the risk of overheating in the housing market and reducing the risk of consumers over-borrowing.
Our Consumer Protection Code also provides an additional layer of protection for consumers, as we require lenders to carry out an assessment of affordability to ascertain the personal consumer’s ability to repay the debt over the duration of the agreement. We also require lenders to test at the point of sale the consumer’s ability to repay the mortgage if there was a 2% interest rate increase.
Making good decisions about financial services and products can be difficult, it can be complex and hard to navigate through the information and the available options.
Recognising this, the Central Bank acknowledges the important role the CCPC continues to play in helping consumers, particularly vulnerable consumers, to help themselves by promoting a greater focus on financial literacy levels, financial education and inclusion initiatives so that consumers are better placed to make informed choices on financial matters.
Through our extensive and proactive public information media campaigns, we too undertake a complementary role by making consumers aware of potential issues that may affect them. A key recent example of this was when we published our research report on the Consumer Experience of Purchasing Gadget Insurance, in December last year. This report has and continues to receive extensive nationwide and online media coverage. It revealed that the majority of respondents did not understand their gadget insurance cover and highlighted some potential pitfalls, which consumers could avoid if they were considering purchasing it.
Restitutions: €164m returned to consumers in just four years
I mentioned earlier that the Central Bank requires regulated entities to correct errors and to refund customers when they make such errors. Our watchful eye is keenly trained on firms making good to customers where it is right to do so.
Excluding the Tracker Mortgage Examination, the figures show that firms have returned €164 million to consumers over the last four years following errors.3 Of this, firms identified and reported €75 million, while the Central Bank identified €89 million through our own supervisory activity.
It is good to see that many firms are complying with the Consumer Protection Code by self-reporting errors and redressing consumers. However, I think you will agree that ongoing supervisory vigilance is needed to ensure compliance with the rules.
Tracker Mortgage Examination: €316m returned to consumers and counting…
A mortgage is the most significant financial commitment for most families and individuals. Consumers have a right to expect their lenders to treat them fairly. That is why, after pursuing tracker issues with a number of individual lenders through extensive supervisory and enforcement work, the Central Bank put in place a comprehensive framework for lenders and launched the industry-wide Examination.
As the largest, most complex and significant consumer protection review undertaken by the Central Bank to date, the Examination has exposed unacceptable failings by lenders on an industry-wide basis.
By December last year, lenders been forced to pay €316 million in redress and compensation to 33,700 customers after they wrongly denied them valuable tracker mortgage products or charged the wrong rate.
These failings have had a detrimental and, in some cases, devastating impact on tracker mortgage customers, up to and including the loss of homes and properties.
The Examination has proved costly for lenders from both a financial and reputational perspective. In our January update to the Joint Oireachtas Committee, the Central Bank reported that the main lenders had made combined provisions of about €900 million in respect of the Examination, broken down as approximately €600 million for redress and compensation and €300 million for costs.
The Central Bank will later this month provide a progress report on the Tracker Mortgage Examination. And next month we will appear before an Oireachtas committee to answer any questions that your public representatives may have on the issue.
In the meantime, we are already conducting enforcement investigations into all the main lenders in relation to the Tracker Mortgage Examination. In our enforcement investigations, the Central Bank will consider all possible angles, including potential individual culpability.
More generally, it is imperative that individuals in positions of responsibility in financial services firms are committed to and demonstrate the highest ethical standards of practice and behaviour.
In that regard, the Central Bank plays an important gate-keeping role in ensuring that the senior management in our financial institutions comply with our fit and proper regime. Since 2012, for example, following fitness and/or probity concerns raised by supervisors in relation to proposed appointments to Pre-Approval Controlled Functions in regulated firms, we robustly challenged those applications, and 45 proposed appointments were subsequently withdrawn.
Our supervision of individuals has also proven to be robust: the Central Bank has issued and published three prohibition notices following fitness and probity investigations.
This assertive risk-based supervision of firms and individuals is backed up by a credible threat of enforcement. Since 2006, the Central Bank has concluded 117 enforcement cases under its Administrative Sanctions Procedure and imposed over €61.6 million in fines.
It is clear from the outcomes I have mentioned that the Central Bank’s regulatory reach extends to individuals as well as to firms. We take individual accountability very seriously and our fitness and probity investigations demonstrate our resolve to act where an individual’s conduct falls below expected standards.
Importantly, the facts of our enforcement outcomes against individuals and firms are the subject of public statements on the Central Bank’s website. We publish the outcomes of enforcement cases to promote compliance across the whole industry and to act as a deterrent against future misconduct.
While many of you are aware of our role in relation to taking action against regulated firms, you may not be aware that the Central Bank also has a dedicated team, which investigates instances of alleged unauthorised activity, carried out by entities or individuals who do not hold any authorisation from the Central Bank. When necessary, the Central Bank takes appropriate enforcement action in relation to such unauthorised activity, such as the publication of warning notices on the Central Bank website. Since obtaining the necessary legal powers in August 1998, the Central Bank has published the names of 310 unauthorised firms.
Conduct and Culture
The apparent regularity with which misconduct issues have surfaced in the years since the crisis means that public trust in financial institutions remains very low.
The recent scandal at US bank Wells Fargo, which was opening accounts in customers’ names without their permission, is a case in point. Wells Fargo set its sales teams the task of selling eight products to each customer and tied employee compensation and bonuses to reaching this target. It worked partly because the goal of meeting the target had the effect of shielding employees from considering the ethical implications of opening accounts that clients neither wanted nor knew about.4
The tracker mortgage scandal here in Ireland has also raised questions about whether the culture in our financial institutions is sufficiently focused on the consumer interest.
These persistent conduct issues have prompted regulators worldwide to consider whether intrusive regulation and compliance measures are sufficient if we are to deliver on our goal of requiring regulated firms to act in the best interests of consumers.
Increasingly, the international regulatory focus is on transforming the culture in the financial services sector.
It is hard to define what we mean by culture, but we all know a rotten culture when we see it – just think of Leonardo di Caprio in the role of Jordan Belfort in The Wolf of Wall Street.
At the Central Bank of Ireland we think of culture as the assumptions, values, expectations and beliefs, which drive the behaviours of staff.
However you define it, culture is these days widely seen by regulators as a key root cause of the major conduct failings in the financial services industry. 5
The question of how firms can effect real cultural change for the better is not one to which there are always simple answers, though much of the current thinking focuses on the importance of a firm’s purpose, leadership and governance in influencing the culture.
Other research has shown that certain blind spots can hinder balanced decision-making and prevent fair treatment of customers. These blind spots are the result of board members having a shared frame of reference which can lead to tunnel vision.6 I would suggest that greater diversity in the boardroom might act as a mitigant in that regard.
There are also questions around the role that incentives play in driving behaviour.
The role of reward in driving behaviour has promoted some interesting developments at TSB in the UK after research carried out by the bank found that 95% of consumers felt that banks put profits before people.7 The TSB has since taken the bold decision to scrap all sales targets, sales linked rewards and access to comparative sales data at a branch and area director level. Instead, TSB has chosen to reward its staff based purely on the service they give to customers.8
Last month, the UK Banking Standards Board published the findings of its Annual Review9 and stressed the importance of leading by example. It found that people are more likely to believe that their organisation lives its values if they observe their leaders doing the same. It is not what leaders in the organisation say that makes the difference, but how they are seen to behave. It also noted that while some employees do not speak up for fear of the negative consequences, the belief that nothing will be done even if they do speak up, is an equally important barrier to doing so.
In the wake of the tracker mortgage scandal, the Central Bank is conducting a review of the culture in the five main retail banks. The review is underpinned by our enhanced Consumer Protection Risk Assessment model which helps us determine how firms identify and manage consumer risks, including the risk that a firm’s culture does not promote and support the protection of consumers.
The Central Bank is working with the Dutch Central Bank, recognised leaders in behaviour and culture, who are participating in onsite inspections at lenders. We will engage with the firms’ boards and senior management to ensure there is a clear focus from the top on embedding and measuring firms’ own cultural change programmes.
This review will shape our future supervisory and engagement strategy. Depending on what we uncover, we may require certain mitigating actions at our lending institutions. These could include, for example, requiring the lenders to conduct an annual internal audit of culture; requiring the boards of the lenders to set up ethics sub-committees; and linking incentivisation to appropriate behaviours.
We are also considering the merits of a Senior Managers Regime similar to the one in the United Kingdom. Such a regime would permit the Central Bank to require senior managers to submit a statement of responsibilities that clearly states the matters for which they are responsible and accountable. These requirements would assist in assigning responsibility to individuals in a regulatory context and decrease the ability of individuals to claim that the blame for wrongdoing lay elsewhere.
The vast majority of those working in the financial services sector are people who want to do the right thing by their customers, their shareholders, their communities and the economy in which they and their families work and live. I am confident that with the right leaders setting the right tone from the top at our financial institutions, spurred on by a watchful regulator with an appropriate regulatory framework, that we can deliver far better protection for consumers in the future than they have experienced in the past.
3: Over the last four years, we have been publishing data broken down between restitutions made on foot of errors reported by firms and restitutions made on foot of issues identified by our own supervisory activity.
4: The role of reward, capabilities, and environment in driving behaviours by Dr. Celia Moore, Associate Professor and Academic Fellow, Ethics and Compliance Initiative, Department of Management and Technology cited in Financial Conduct Authority’s Discussion Paper DP18/2
5: Financial Conduct Authority, Transforming Culture in Financial Services, Discussion paper DP 18/2
6: Balanced decision-making: dealing with blind spots: A study within management boards of small and medium-sized banks, AFM (The Dutch Authority for the Financial Markets), December 2017
7:YouGov survey of over 2000 people conduct for TSB (2013)
8:The role of reward in driving behaviour by Paul Pester, CEO TSB and Rachel Lock, HR Director TSB, quoted in Financial Conduct Authority Discussion Paper DP18/2