Update on IRHP final report

John Swift QC, the Independent Reviewer appointed in respect of the review of the supervisory intervention on Interest Rate Hedging Products, has now completed his discovery exercise and recently provided the FCA with his draft report.

There will now be the usual fact-checking and representations process with the report expected to be finalised and published in summer 2021.

The FSA/FCA’s intervention on Interest Rate Hedging Products involved a number of regulated entities and skilled persons and covered the six-year period from 2012 to 2018.

Since the start of the Independent Review, in July 2019, the FCA has provided John Swift QC and his team with approximately 1 million documents, over a 15-month period from this date, that were potentially relevant to his review.

John Swift QC has also conducted a large number of interviews with stakeholders including former and current FSA/FCA employees, IRHP customers, banks and skilled persons.

However, the number and the complexities of the issues under review, and the large volume of material to be considered and analysed, and the effects of the coronavirus (Covid-19) pandemic over the whole of last year, presented challenges for the provision of documents and the conduct of the Independent Review. This combination of circumstances has meant the Review has taken longer to progress than was initially anticipated.


The Review was commissioned on 20 June 2019 by the Non-Executive Directors of the Financial Conduct Authority (FCA).

John Swift QC was appointed on 20 June 2019 to carry out the Lessons Learned Review into the supervisory intervention on IRHPs.  Under the Terms of Reference, the Review was to be completed within a period of 15 months beginning on the date Mr Swift was appointed by the FCA.

Under Paragraph 9 of the Terms of Reference, if the Independent Reviewer considered that it was not be possible to complete the Review within the period of 15 months from 20 June 2019 (i.e. by 20 September 2020), he was required to inform the FCA of:

(a) the reasons for the delay in the conclusion of the Review; and

(b) a revised target date for the conclusion of the Review.

The target date was previously revised on 20 March 2020 to early 2021.


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