Court minutes from 2021 that were previously redacted

Since April 2013 Court has been required by Paragraph 12 of Schedule 1 of the Bank of England Act to publish minutes of its meetings. The Act also provides that Court may withhold information from publication where this would in its opinion be against the public interest. Material has been withheld from publication under this provision and, absent further action by the Court, would not enter the public domain until normal archive release after 20 years. However at its meeting in December 2015, Court adopted a process for keeping past redactions under review. At its meeting in December 2023 Court decided that a number of items withheld in 2021 should no longer be withheld and these are reproduced below, with context where necessary. A further review, of items redacted in 2022, will be undertaken December 2024.

Text in bold has already been published.

10 February 2021

Minutes and Matters Arising

Jo Place updated Court on the review of pension provision. It had already been decided to reduce the opt-out rates in stages.

Andrew Bailey said that he had been concerned to find that the publication schedule for Governors’ and Directors’ expenses, gifts and entertainment had slipped: this was being rectified.

Report from Audit and Risk Committee (ARCo)

…VFM assessments. There had been a further discussion of emerging risks: a copy of the paper would be circulated to non-executive Directors not on ARCo for information.

Report from Remuneration Committee (RemCo)

Dido Harding said that the Committee had approved pay awards for the Governors and Executive Directors.

It was noted that RemCo would in future be involved in the approval of settlement agreements above certain limits. It had agreed the pension opt-out rates for the coming year and continued the freeze on flex rates.

The Bank’s Finances

(Nat Benjamin, Afua Kyei, Kevin Moossa and Paul McArdle)

(a) 2021/22 Budget

…It had been helpful in this round to look at current and capital expenditure together, along with income streams: Finance was now providing numbers that made such planning more effective.


(b) Update on FRF and Supervision of New Firms

(Vicky Saporta, Anna Sweeney, David Bailey, Simon Morley, Mel Beaman, Phil Evans, Alex Fernandes and Gary Moore)

…the Treasury had launched a review of the Solvency II regime for insurers.

Vicky Saporta added that the process was an opportunity: the UK had challenged some aspects of EU regulation and this was an opportunity to make adjustments that were appropriate for the UK while maintaining our commitment to high standards, including in particular for smaller banks, given the PRA’s secondary competition objective.

Similar issues arose in FMI supervision. The Bank’s responsibilities would grow as non-UK FMIs were “recognised” by the Bank. But the primary legislation was less detailed and the Bank could follow international standards.

Notes – Future Distribution Infrastructure Review

(Sarah John, Dominic Whittle, Toby Davies, Allison Curtiss and Mark Piper)

Sarah John said that the lease on the Leeds cash centre building would expire in 2023. A review of note distribution capacity – taking account of the longer life of polymer notes and the decline in the transactional use of cash – had concluded that the Bank could manage with a single cash centre at Debden. The Union would be consulted in April about possible redundancies.

The Bank’s Regional Footprint

(Jo Muir, Jane Cathrall and Andrew Hebden)

Andrew Bailey said that ExCo had discussed expanding the Bank’s geographical presence across the UK. There were a number of factors – one was that experience during the Covid period had made offsite working more acceptable. A second was that the Bank’s regional presence was very limited. Against this background Governors had been considering options and the work remained at an early stage.

The Chair asked whether the proposal was to move a specified function of the Bank or to create serviced office space for use across functions – and whether (if the former) the Bank could benefit from proximity to university hubs. Ron Kalifa said that this was a significant initiative and to be successful it would need to be properly owned and led, ideally by a Deputy Governor. Frances O’Grady agreed – experience of relocation elsewhere had been mixed; it was important to consult with staff; there were implications for diversity targets; and politically it would play into the Federalism debate. Anne Glover said that the prior question was how much the Bank was moving and for what objective.

Andrew Bailey thanked Court members for their thoughts. He took it that there was support for the intention subject to clarity on (1) the objective (2) the slice vs function question (3) the proposed business model and (4) securing high level ownership. All of these ExCo intended to consider further.

14 April 2021

Minutes and Matters Arising

Court noted Andy Haldane’s appointment as chief executive of the Royal Society of Arts (RSA). Andrew Bailey said that he would be leaving the Bank at the end of June and join the RSA in October following a period of restricted duties, consistent with the MPC Code. He would avoid any public comment on MPC matters until January 2022. Court recorded its thanks…

Report from Audit and Risk Committee (ARCo)

Dorothy Thompson said that good progress had been made on the audits of the 2020/21 accounts, including the (Treasury-indemnified) BEAPFF and the CCFF subsidiaries which were audited by the NAO. Expected loss on the CCFF scheme was not expected to be material. Climate disclosures across all the Bank’s reporting were still to be reviewed…

Report from RTGS Renewal Committee (RRC) and approval of Terms of Reference

(Victoria Cleland and Rob Elsey)

Sarah Cox had been appointed Programme Director, replacing Nick Lodge.

Report from Remuneration Committee (RemCo)

Andrew Bailey had not received any pay increase as part of the annual review as he had been less than a year in post.

PRC Strategy 2021/22

(Alex Barnett and Clair Mills)

Court was content the PRA strategy for 2021/22. It would be published as part of the PRA business plan in May.

Sam Woods said that the PRA was sharing out central functions among Executive Directors ahead of Lyndon Nelson’s departure. One of these would be to support the PRA’s use of data. The Chair asked how this fitted with Gareth Ramsay’s Bankwide responsibilities for data; was this an example of central/local duplication just discussed in relation to central services? He asked for Gareth Ramsay to give a progress report at May Court.

Diversity Review

(a) Communicating Assessment Findings

(Jenny Scott, Jamie Bell, Amar Radia, Jenny Pye, Sian Jones, Jerusalem Gebremeskel, Ragveer Brar Jacqueline Koay, Will Abel, Nishat Anjum and Sagar Shah

Diana Noble updated Court on progress of the review. She outlined plans to send the assessment to all staff, as part of a process by which relevant networks, staff and management could share the analysis and collectively reflect on the recommendations and actions. It was suggested that the release to staff be accompanied by a statement underlining the importance of all staff being involved in the response. This would come from herself and Andrew Bailey, underlining the importance that Court and Senior Management attach to the issues, the progress already made and the need to address the issues identified. Dave Ramsden and Sam Woods agreed to work with the relevant networks as part of this, with the involvement of Ragveer Brar, Jacqueline Koay and Amar Radia.

Directors praised the quality of the analysis and the contributions of the review team.

Andrew Bailey noted that there had been progress in tackling gender inequality at the Bank, but talent had been built over a period of years and that timetable might not be available in the present case. The analysis of what had happened was important, but the focus should be on what needed to and would happen.

(b) Communications

(Jenny Scott and Jamie Bell)

Andrew Bailey and Diana Noble would jointly front the Review internally and would need to walk a fine line – not exaggerating but equally not trivialising the issues. Frances O’Grady said that the TUC had conducted a similar exercise which had proved successful and offered to work with the communications team to discuss effective language.

Roehampton Site

Court noted with approval the grant of a 15-year lease of the Roehampton site to the All England Lawn Tennis Club.

26 May 2021

Minutes and Matters Arising

It was noted that a further pooled recruitment process was underway for Head of Division (HoDs) vacancies. In this context Ron Kalifa thought it important to consider whether the Bank had sufficient HoDs in place to support some of the Executive Directors whose roles had become increasingly demanding.

Remuneration Committee (RemCo)

(a) Report from RemCo

Dido Harding said that Remco had met the previous day to approve the new ED salaries, and had approved salary for Jane Cathrall and acting up allowance for Rebecca Jackson and Duncan Mackinnon.

Diversity Review

(Amar Radia, Jenny Pye, Jerusalem Gebremeskel, Will Abel, Nishat Anjum, Sagar Shah, Ragveer Brar, Jacqueline Koay, Jane Cathrall and Cat Hines)

Further to a discussion in Court in December, Jane Cathrall outlined a proposed strategy for setting diversity targets.

Jacqueline Koay and Raj Brar, as co-Chairs of the BEEM network, stressed that the record on promotions to Scale C+ over recent years had not been encouraging: and the targets needed in their view to be stretching. Court accepted that the targets would be challenging and the hard part would be meeting them: Andrew Bailey said a long-term anchor was necessary. Directors noted that there would need to be careful consideration of the methods to achieve the targets. The forthcoming staff viewpoint survey should explore these matters further. The Review Team were asked to consider methods for internal consultation of the final recommendations.

Diana Noble said that final key findings and recommendations would be presented to Court in July. She recommended the creation of an oversight forum to set yearly priorities across all protected characteristics (disabilities, age, LBGTQ).

15 July 2021

Matters Arising

(Sonya Branch and Oliver Dearie)

Sonya Branch advised that the Upper Tribunal had ruled against the PRA and the FCA in the matter of an enforcement case made against an individual involved with the Scottish Boatowners Mutual Insurance Association. There was no indication that the regulators had erred in law, but the Tribunal had been critical of their approach to disclosure and evidence handling, and questioned whether it was proportionate for this case to merit a joint investigation.

Oliver Dearie, the new head of the Enforcement and Litigation Division (ELD), added that lessons-learned reviews would be conducted both individually as well as in conjunction with the FCA, and that the appropriate checks would be made to the existing pipeline of cases. Priority would be given to acquiring an Evidence Management system for ELD.

Sam Woods commented that the disclosure failings needed to be addressed specifically, and that appropriate consideration should be given to the criticisms. Dorothy Thompson added that the issues would be brought to ARCo’s meeting in September.

The One Bank Services Transformation Programme (OBST)

(Jonathan Curtiss, Rob Elsey, Nat Benjamin, Lorraine Barclay, Steve McGowan, Paul Rooney and Afua Kyei)

Jo Place explained that this was an uncomfortable read, but that she hoped the level of transparency provided Court with some reassurance. She advised that since January there had been a change to the project’s executive sponsor, with herself assuming that role, a ‘lessons learned’ analysis, a split of the work into HR and Finance streams. She had a high degree of confidence that the HR element of the programme would be delivered in the autumn.

Jonathan Curtiss confirmed that 95% of the User Acceptance Testing (UAT) of the HR system had been completed. Processes like Data Migration had been optimised. A significant fix in respect of absence management had been implemented and was back in UAT. Ron Kalifa queried the roll-back contingency plan. Jonathan Curtiss replied that safe deployment was a priority, but that there was a roll-back plan. The team would update Court on this aspect of the programme in September.

Lorraine Barclay, the newly appointed Head of Transformation, said that she had built a relatively small team and proposed to effectively restart the Finance programme. She intended to present a project plan to ExCo which would take account of the complex interdependencies between CODA (the current general ledger) and business systems, and which would aim to make the new general ledger less congested and more agile. Court endorsed the resetting of the Finance plan.

Bank of England Funding

(Paul Brione, Nat Benjamin, Paul McArdle, Afua Kyei and Stephen Fishbourne)

Dave Ramsden noted that the CRD scheme was becoming increasingly ineffective as a source of income for the Bank’s policy functions, owing to persistently low gilt yields. In discussion with the Treasury, work was in hand on a fee-based system, similar to that of the PRA. The timing was uncertain as it would require a change to primary legislation. One of the main decisions to be made related to which firms would be in scope for the payment: there were around 150 firms with access to the Bank’s liquidity facilities, but the Treasury was considering broadening this to include a number of insurers.

Quarterly Financials

(Nat Benjamin, Kevin Moossa and Afua Kyei)

Kevin Moossa advised Court that spending had been running below budget in the first quarter (March-May), mainly reflecting delayed investment spend and recruitment shortfalls, updated the full-year 2021/22 forecast. Realised savings to date would be re-deployed to fund the incremental costs associated with hybrid working, the Court D&I review recommendations, regional working, and the HR component of the OBST project.

Papers for Information

Court noted:

• MPC Report

• Update on the Media Incident (Encoded Media) actions

• Bank/FRC MoU

20 September 2021

RemCo Update

Dido Harding updated Court on Remco’s most recent meeting. One settlement agreement had been approved under the Bank’s governance procedures; and the Committee had approved the pay arrangements for Huw Pill. Several members noted recruitment pressures in specialist areas, both in Technology and in the PRA.

Regional Footprint – location of Northern office

(Tani Hussain, Andrew Hebden and Simon Heywood)

Further to a discussion on 15 July, Jo Place set out the analysis so far conducted on Leeds as a location for the Bank’s Northern hub. Leeds had previously been identified as the most likely location, and the analysis so far supported that. Court members stressed the importance of a clear strategy, business case and VFM assessment: and the need to achieve critical mass in the new location. The assessment should therefore take account of the Bank’s current experience of hybrid working, which had made location less of an issue. We knew which activities of the Bank needed to be in London, including from experience during the recent past, and the rest could in theory be delivered from another centre. But the VFM assessment should also consider the limitations of the Threadneedle Street building, which would not be easy to sub-divide given security issues.

Summarising the discussion the Chair said (1) that Leeds was a reasonable place to go; (2) that any decision on the scale and scope of the presence would be subject to scrutiny, and a robust VFM assessment would be expected; and (3) the Bank needed to build in flexibility until there was real comfort around the business model.

29 October 2021

Minutes and Matters Arising

COO appointment

Court welcomed the appointment of Ben Stimson as the Bank’s Chief Operating Officer, noting in particular his background and experience in digital transformation.

Remuneration Committee (RemCo) Update

Dido Harding noted the Committee had agreed salaries for Ben Stimson as COO, and for Nathaniel Benjamin and Duncan MacKinnon as new EDs.

RTGS Renewal Programme

(Victoria Cleland, Afua Kyei, Oliver Tweedie and Sarah Cox)

…Firms needed to be ready and they would be consulted in January 2022 about the timing of the next stage.

The work delivered by Accenture as a third party support for the project was discussed – it seemed to be progressing well, and Court asked for an update on any key lessons that could be useful for future Bank projects.

Update on the Data Analytics Programme

(Gareth Ramsay and Peter Eckley)

Gareth Ramsay updated Court on the Data Analytics Programme. The Programme was intended to make it easier for staff to get the data they need, and to use it efficiently. The approach was driven by small initiatives rather than big ones given the multiplicity of data sources and of analytical tools: highlighting in particular the 2022 / 23 work programme, which envisaged stepping up the pace of investment and training. Andrew Bailey said that the Programme had been squeezed in the previous year’s budget but would not be in the current budget: there needed to be an investment. The vision was to widen and facilitate access to data of all types, and to provide tools and training that would enable the best use to be made of it. Without this we risked losing staff simply because they are not properly supported. Sam Woods added that the investment would free up people’s time and increase their impact – and also avoid mistakes. This was not a Big Bang – it was a tactical upskilling.

Ron Kalifa commented that the Bank was a policy institution driven by data and it needed a data strategy. A lot of organisations were using data sources but a clear end-target was needed to drive change. Anne Glover said that the paper was helpful but asked what additional resources might be required to support more transformative targets over the longer term. Gareth Ramsay said that the team had built a data platform, which was the first step towards a long-term strategy.

Court welcomed the progress made and requested a further update in May 2022.

2 December 2021

Regional update

(Jo Place, Tani Hussain, Simon Heywood, David Shepherd and Hehtal Patel)

Court discussed the Bank’s proposed northern hub. Court agreed objectives and key milestones, which would be announced in due course. As part of the discussion Court was asked to agree three high level objectives for the proposed northern hub in Leeds: these were to improve: (1) public understanding and trust in the Bank beyond London and the South East; (2) the diversity of the Bank in order to better represent the public it serves; and (3) the Bank’s ability to meet future skills needs. Jo Place said that the key driver was to help the Bank deliver its mission, although in implementation, value for money would underpin all of our objectives. The Governor added that the third objective had increased in importance in the present tight labour market. The hub should give the Bank more access to greater talent across the UK.

Court members suggested several modifications to the wording: (1) rather than refer specifically to the South-East, the first objective should say “across the country as a whole”; (2) the second objective should refer to “the diversity of the Bank and its inclusive culture”. Dido Harding thought that the Bank should continue to focus on shifting the culture of the institution, which meant also changing the way people worked. Ron Kalifa thought that the statement could be bolder on the need for efficiencies. The Chair asked if the three objectives could be prefaced by ‘subject to driving efficiencies, value for money, and exploring new ways of working’. Dorothy Thompson asked that the statement refer to “expanding” the Bank’s regional presence, to reflect the fact that it already had one.

Subject to these points, the high level objectives for the Leeds hub were agreed.


(Afua Kyei, Paul McArdle and Jane Tucker)

(a) 22/23 Budget and DG Targets

(b) High Level multi-year plan

Afua Kyei outlined the 2022/23 budget and DG targets. She flagged the change in the inflation assumption to 3%. Finance had taken account of feedback received at the previous Court meeting.

Dorothy Thompson was supportive of the approach taken and thought the budget had reached a good position. The three year plan needed further development but it was a good beginning. Andrew Bailey noted that the review was constrained not only by capacity and capability. It was necessary that particularly on the investment side the plans fitted around RT, the Bank’s overriding core priority, and that the recruitment assumption was realistic. In support of this, the Bank needed to be prepared to be flexible.

Ron Kalifa asked about other risks to the budget – and CBDC and regulatory reform – and how the numbers were arrived at. The Governor said that CBDC was simply a placeholder for further investigative work. Jon Cunliffe said that if the decision was to go ahead the Bank would aim to put out a technical blueprint, consult, test and deliver. It would take a number of years to go through these stages. In the meantime it was the policy discussion that needed to be advanced. Regulatory reform would also have to be taken forward and could be a big cost. Sam Woods said that the present assumption was tentative as it remained uncertain what steady state would look like.

Afua Kyei said that the Bank needed a more flexible budget framework. The current framework needed to be thought through around the three year plan, with enough flexibility to allow some permanent increases. The investment portfolio was oversubscribed and that too would need to be considered. Dave Ramsden said that the Strategic Priorities process had delivered, but there remained considerable stress in resources and people in a number of areas of the Bank, particularly in Technology. Diana Noble noted that competition for talent had materially increased, so our recruitment teams had to be of high quality and sufficiently supported.

Post-Brexit stocktake – Financial Regulation

(Sam Woods and Hugh Burns)

The Chair asked about scrutiny and how to think about it, and Dido Harding asked if there were any indications of the form it might take. The Governor said that the Bank had been trying to get the issue of accountability on the agenda for some time. Jon Cunliffe said there would be the same issues on the market infrastructure side. In the context of Basel III… … in the financial system and wider economy. As the debate continued Court would be consulted if there were concerns about any impact on our effectiveness.

Social mobility

(Jane Cathrall, Paul Wright, Amy Sinclair, Jess Beynon, Rachel Butler and Sian Jones)

..Broadening the ways in which we attracted talent would build a more diverse and inclusive Bank. Jo Place said that the Bank had recently increased the number of apprentices. She agreed that more should be done, and Anne Glover thought it might be consistent with addressing the talent gap in Technology – an important strategic aim. It would be important to have clear KPIs and to measure outcomes so that it was clear what was working and what was not. Paul Wright said they had set out some KPIs and would build on them.


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Minutes of the Meeting of the Court of Directors held on 14 December 2023

David Roberts, Chair

Andrew Bailey, Governor

Sarah Breeden, Deputy Governor – Financial Stability

Ben Broadbent, Deputy Governor – Monetary Policy

Sir Dave Ramsden, Deputy Governor – Markets & Banking

Sam Woods, Deputy Governor – Prudential Regulation

Jonathan Bewes

Sabine Chalmers

Lord Jitesh Gadhia

Anne Glover

Sir Ron Kalifa

Diana Noble

Frances O’Grady

Tom Shropshire

In attendance:

Ben Stimson, Chief Operating Officer


Sebastian Walsh

1. Conflicts, Minutes and Matters Arising

There were no conflicts declared in relation to the present agenda.

The minutes of the meeting held on 31 October 2023 were approved.

The Chair welcomed Sarah Breeden to her first meeting of Court as Deputy Governor for Financial Stability.

Court expressed its thanks to Andrew Hauser, shortly to become Deputy Governor of the Reserve Bank of Australia, for his important contributions to the work of the Bank of England.

2. Governor’s Update

The Governor updated Court on the principal elements of the Bank’s Financial Stability Report, published on 6 December.

The Governor noted that the Bank had also, since the last Court meeting, released a hypothetical scenario for its system-wide exploratory scenario exercise, which would assess the behaviours of banks and non-bank financial institutions during stressed financial market conditions and how they might interact to amplify shock to markets core to UK financial stability.

The Governor added that the Bank had published a policy statement on Basel 3.1, noting the PRA was doing further work on the subject.

The Governor updated Court on a number of remuneration issues.

Court discussed priorities for the year ahead, noting that investment in technology and the pensions review should be important points of focus.

3. Nominations Committee (NomCo) Update

The Chair updated Court on the NomCo meeting of 31 October, which focussed on succession planning for the Bank’s most senior roles.

4. Audit and Risk Committee (ARCo) Update

Jonathan Bewes updated Court on the ARCo meeting of 22 November, where it has been updated on the progress of RTGS renewal and the five-year review of the Bank’s capital framework. It had also discussed the Bank’s risk register, its third-party suppliers and process risk within the organisation.

5. Remuneration Committee (RemCo) Update

Diana Noble updated Court on the work of RemCo.

Diana Noble noted that RemCo had been closely engaged on the development of the Pensions Review. RemCo had also approved salary reference points for executive directors, as well as agreeing remuneration for members of the new Financial Market Infrastructure Committee.

6. RTGS Renewal Programme

(Victoria Cleland, Nathan Monk and John Stocker)

The Chair noted that an update on the value for money considerations around RTGS renewal had been requested by Court at a previous meeting.

John Stocker noted that Value for Money had been considered from the very early stages of RTGS renewal, and had a methodology aligned to that of the National Audit Office. Court commended the approach taken by RTGS Renewal as an example of high-quality project management for large scale programmes.

Victoria Cleland noted that work was on-going to explain the benefits renewal would bring to industry and key stakeholders, with an emphasis on ISO20022.

Anne Glover observed that it could be helpful to explain the benefits of our renewed RTGS in comparison to the functionality offered by other central banks.

In response to questions, Victoria Cleland noted that quality and scope of the build had been prioritised.

The Governor noted that the benefits of RTGS would be acknowledged in future, by enabling the Bank to encourage innovation and competition in the banking sector.  The Chair agreed, noting the relevance of the PRA’s new statutory objective to promote growth and competitiveness in this respect, as well as the Bank’s new secondary objective to facilitate innovation in the provision of Financial Market Infrastructure services.

  • RTGS Renewal Programme Update

Victoria Cleland said that good progress had been made on TS3 since the previous Court meeting, particularly with regards commencing the testing by participants.

Internally, testing “model office” was underway. She noted that a key milestone would be whether Participant Acceptance Testing could begin as planned in January.

Frances O’Grady asked whether risks around staff retention had grown as the project approached its conclusion, as people looked for new roles. Victoria Cleland said that an approach had been agreed to help staff transition to other roles within the Bank after the project concluded.

The Chair thanked Victoria Cleland for the update.

7. COO Update

(Nathan Monk)

Ben Stimson updated the progress of CS2025 and the work of Central Services, highlighting progress in Technology and Data.

Ben Stimson also brought a number of programmes to Court for approval. He highlighted the Enterprise Integration Programme. Court discussed and approved the project, noting its foundational nature for the transformation of technology.

Court approved the data centre co-location services programme and Azure Cloud Platform Services programme, and the renewal of contract with LSEG/Refinitiv.

Court also discussed the renewal of the Bank’s energy contract. Court NEDs requested a short update on the costs and benefits of different, more flexible approaches to that outlined. Court also discussed the important intersection between this and the Bank’s property strategy.

Huw Pill joined Court to discuss renewal of FAME, a system which supports much of the Bank’s analytical work, including the MPC’s forecasting process. He said work was underway to scope and design a new modular system to support the Bank’s analytical areas in future. Court noted the budget was approximate at this stage, but gave its approval for the work to move forward given its critical importance to the Bank’s ability to acquit its responsibilities.

8. Technology Modernisation Update

(Nathan Monk and Pete Townsend)

The Chair welcomed Nathan Monk and Pete Townsend to the meeting, who provided Court with an update on the Technology Modernisation Programme.

Since September’s meeting, Nathan Monk and Pete Townsend had progressed a plan for sustained investment over the next five years. In particular, work regarding cloud and data centres had progressed at pace.

Court asked for the next update to include further detail on how other business areas would be involved in this Technology programme and how interdependencies were being considered. Members also asked for more detail on how the programme would be managed and governed, as well as its risk register.

9. Pension Review

(Jane Cathrall and Natasha Wilson)

Natasha Wilson updated Court on the pensions review.

Diana Noble gave Court members the perspective of RemCo on the review.

The Chair thanked Jane Cathrall and Natasha Wilson for their work to date on the Pensions Review.

10. IEO – next evaluation

(Melissa Davey and Michael Lever)

Melissa Davey informed Court that two areas had been identified for IEO reviews in 2024.

First, the IEO proposed to assess the PRA’s approach to secondary growth and competitiveness.

Second, the IEO planned to assess the Bank’s horizon scanning capabilities.

Court welcomed the proposals.

11. FPC Effectiveness Review 2023

(Sebastian Walsh)

The Chair noted that he had undertaken a regular effectiveness review of the FPC. The Committee was found to be functioning well, with good support from Bank staff.

Sarah Breeden said that, having been newly appointed as Deputy Governor for Financial Stability, she intended to take the opportunity to review the operation of the FPC and would update Court in due course.

12. De-redactions for Court Minutes published in 2021

(Sebastian Walsh)

Sebastian Walsh introduced the item. Court approved the proposed de‑redactions.

13. Committee Appointments and Conflicts

(Sebastian Walsh)

The Chair noted that good progress was being made with regards to the recruitment for the incoming Deputy Governor for Monetary Policy.

The Chair noted that Anne Glover and Ron Kalifa had been appointed to advise the Labour Party’s review of financial services. The Chair set out that appropriate mitigating actions had been pursued to guard against any potential or perceived conflicts of interest.

Court approved the proposed membership of the Financial Market Infrastructure Committee.

Court approved the appointment of Rebecca Jackson as the Executive Director for Authorisations, Regulatory Technology, and International Supervision.

14. Items for Information

Court noted:

  • Monetary Policy Committee Report
  • First annual public release of Warsh Review MPC meeting transcripts and papers January 2024
  • Senior Managers Regime (SMR) – annual attestation
  • MoU/SLA Annual Review

The meeting of Court was closed.


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Statistical Notice 2024/05 | Bank of England

Bank of England Levy: update on implementation

Following consultations by the Bank and HM Treasury on the implementation of the Bank of England Levy to replace the existing Cash Ratio Deposit (CRD) scheme, the Bank of England Levy (Amount of Levy Payable) Regulations 2024 (Regulations) were laid in Parliament on 22 January 2024 and are undergoing Parliamentary scrutiny.

Subject to the completion of the Parliamentary approval process, the Levy and the Regulations are due to come into force on 1 March 2024.

The Bank will provide final confirmation of the implementation date for the Bank of England Levy, and the date that the CRDs will be returned to firms on completion of the Parliamentary approval process, via a Statistical Notice.


A summary of all Statistical Notice items that are yet to come into effect are also available to view on the Statistical notices page. Statistical Notices should be received by all those responsible for the completion of Bank of England returns. To amend the circulation list please subscribe.


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Minutes of Money Market Committee meeting – December 2023


Item 1 – Welcome

The Chair thanked members for attending and confirmed that the Minutes of the September 2023 meeting had been published on the Bank’s website.footnote [1]

The Chair welcomed new members and those who were attending as part of the Bank’s Meeting Varied People (MVP) initiative.

The Chair thanked Jon Pyzer (Bank of England) for his work with the Committee over the past years following the announcement of his retirement.

Item 2 – A possible new Bank of England lending tool for Non-Bank Financial Institutions

Colleagues from the Bank of England presented a summary of Andrew Hauser’s speech on the Bank’s work to develop a new lending tool for Non-Bank Financial Institutions (NBFIs)footnote [2]. The purpose of the tool is to address dysfunction in core sterling markets in the exceptional circumstances where there is a threat to UK financial stability. It will do so by channelling liquidity directly to eligible NBFIs when capacity constraints prevent banks from lending in sufficient size and speed. The tool is not intended to provide bilateral liquidity support to individual NBFIs.

Committee members discussed the potential vulnerabilities in the gilt market, how the Bank can design the NBFI lending tool so that it works effectively alongside existing SMF facilities, and ways in which the Bank could address the scaling up challenges faced in potentially expanding access to the tool to a broad range of NBFIs.

Members shared their thoughts on these issues, in particular on the challenges associated with the large size of the NBFI universe and posed the question of whether the tool should be accessible to all NBFIs or a subset.

Item 3 – Discussion on market conditions

A high-level update on market developments was presented by a member of the Committee which covered recent moves in the UK curve; money market fund flows; and the impact of non-remuneration of ECB reserves on the cross-currency basis.

Several members noted that there a marginal increase in MMF WAMs recently, and that this is likely due to the expectation that the next move in global policy rates is more likely to be down as opposed to up, as well as positioning around the year-end.

Short-end repo market conditions were stated as being benign, with a steady supply and generally healthier repo rates. The increased usage of the STR has been encouraging also as it suggests there is no stigma associated with its use.

Committee members further discussed the level of the Preferred Minimum Range of Reserves (PMRR) and noted that it would be helpful to hear more from the Bank of England on this topic.

Item 4 – Diversity & Inclusion

The Committee had an open discussion on what members’ firms are doing to improve D&I, and whether there are any lessons that can be learnt for the Committee itself. This was led by a D&I lead from one of the member firms.

Members noted how helpful in some circumstances ‘reverse mentoring’ can be to help senior, non-diverse colleagues understand the perspectives and difficulties of others. Several members also suggested that pushing more junior colleagues to speak at relevant forums would also be beneficial.

The Bank of England consultation regarding regulation around diversity metrics was noted as being a potential aid in improving industry-wide D&I.

Item 5 – Money Markets Code Review Update

A representative of the Money Markets Code sub-committee provided and update on the ongoing Money Markets Code review working groups which have been meeting in recent weeks, as well as setting out the review’s next steps and governance ahead of the March MMC meeting.

It was noted that the review will not be a complete rewrite, instead reflecting changes to market approaches and practices since the current document was publishing in 2021.

Draft changes to the Code will be circulated to all MMC members and the relevant trade associations and other stakeholders before publication, and will require MMC sign-off, which is expected to be in the first half of 2024.

Item 6 – Any other business

The Committee discussed HMT’s Autumn Statement regarding the UK short selling regime work following HM Treasury’s consultation paper on its Short Selling Regulation Review.

A Bank of England representative provided a brief update on the Bank and the FCA’s joint CP on Money Market Fund Resilience which was published earlier in the day.

The Chair thanked members for their time and welcomed any suggestions for future agenda items to be sent to the Secretariat in due course.

Committee attendees

James Winterton – Association of Corporate Treasurers

Emma Cooper – BlackRock

Niamh Staunton – BP

Romain Dumas – Credit Suisse

Inna Shaykevich – Goldman Sachs

Evelyn Liang – Goldman Sachs (MVP Invitee)

Victoria Worsfold – Guildford Borough Council

Chris Brown – Insight Investment

Olivia Maguire – J.P. Morgan Asset Management

Wael Damiati – LCH (Alternate)

John Wherton – Legal & General Investment Management

Scott Creed – Lloyds Bank

Natasha Mirchandani – Lloyds Bank (MVP Invitee)

Joanne Gaskin – Lloyds Bank (MVP Invitee)

Nina Moylett – M&G

Oliver Butcher – NatWest

Sunil Kumar – NatWest (Presenter)

Nic Erevik – Newcastle Building Society

Chirag Patel – Rabobank

Alan Williams – Santander UK

Romain Sinclair – Société Générale

Kokou Agbo-Bloua – Société Générale (Presenter)

John Argent – Tradition

Jessica Pulay – DMO (Observer)

Alan Barnes – FCA (Observer)

Bank of England

Andrea Rosen (Chair)

Jon Pyzer

Simon Dolan

David Glanville

Grace Greer

Tom Archer

Clare Macallan (Presenter)

Nick Butt (Presenter)

Steven Dodkins (Presenter)


Gordon Lowson – Abrdn

Ina Budh-Raja – BNY Mellon

Marije Verhelst – Euroclear

James Murphy – HSBC

Tony Baldwin – LCH

Avi Tillu – PIMCO


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Statistical Notice 2024/03 | Bank of England

Preparation for transition from Cash Ratio Deposit scheme to the Bank of England Levy 

1. Introduction – closure of Cash Ration Deposit scheme and start of the Bank of England Levy

As flagged in the Bank’s Consultation Paper dated 8 November 2023, the current Cash Ratio Deposit (CRD) scheme will be replaced by the Bank of England Levy (Levy) (subject to Parliamentary approval). When the CRD scheme ends, the Bank will return all CRD deposits it holds to CRD payers. 

2. How will CRD deposits be returned by the Bank to CRD payers?

The method used by the Bank to return the CRD deposits will depend on the repayment details currently held for each relevant deposit-taker, but will be a payment by the Bank via:

  • BACS, or
  • CHAPS, or
  • to a deposit-taker’s Reserve Account in RT. 

3. What do I need to do now to prepare for the return of the CRD deposit?

In preparation and to facilitate this process, current CRD payers are requested to advise the Bank of any changes to contact or repayment details by the 14 February 2024.

Any changes to payment instructions should be signed in accordance to your signature mandate and emailed to or alternatively sent by authenticated SWIFT message to BKENGB2L, to be sent no later than 14 February 2024. 

4. When will the levy be implemented and the CRD deposit returned?

The Bank will confirm the Levy implementation date on completion of the Parliamentary process.

Any questions regarding the repayment process should be emailed to


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Bank rate maintained at 5.25% – February 2024

Monetary Policy Summary, February 2024

The Bank of England’s Monetary Policy Committee (MPC) sets monetary policy to meet the 2% inflation target, and in a way that helps to sustain growth and employment. At its meeting ending on 31 January 2024, the MPC voted by a majority of 6–3 to maintain Bank Rate at 5.25%. Two members preferred to increase Bank Rate by 0.25 percentage points, to 5.5%. One member preferred to reduce Bank Rate by 0.25 percentage points, to 5%.

The Committee’s updated projections for activity and inflation are set out in the accompanying February Monetary Policy Report. These are conditioned on a market-implied path for Bank Rate that declines from 5¼% to around 3¼% by the end of the forecast period, almost 1 percentage point lower on average than in the November Report.

Since the MPC’s previous meeting, global GDP growth has remained subdued, although activity continues to be stronger in the United States. Inflationary pressures are abating across the euro area and United States. Wholesale energy prices have fallen significantly. Material risks remain from developments in the Middle East and from disruption to shipping through the Red Sea.

Following recent weakness, GDP growth is expected to pick up gradually during the forecast period, in large part reflecting a waning drag on the rate of growth from past increases in Bank Rate. Business surveys are consistent with an improving outlook for activity in the near term.

The labour market has continued to ease, but remains tight by historical standards. In the February Report projections, the continuing relative weakness of demand, despite subdued supply growth by historical standards, leads a margin of economic slack to emerge during the first half of the forecast period. Unemployment is expected to rise somewhat further.

Twelve-month CPI inflation fell to 4.0% in December 2023, below expectations in the November Report. This downside news has been broad-based, reflecting lower fuel, core goods and services price inflation. Although still elevated, wage growth has eased across a number of measures and is projected to decline further in coming quarters.

CPI inflation is projected to fall temporarily to the 2% target in 2024 Q2 before increasing again in Q3 and Q4. This profile of inflation over the second half of the year is accounted for by developments in the direct energy price contribution to 12-month inflation, which becomes less negative. In the MPC’s latest most likely, or modal, projection conditioned on the lower market-implied path for Bank Rate, CPI inflation is around 2¾% by the end of this year. It then remains above target over nearly all of the remainder of the forecast period. This reflects the persistence of domestic inflationary pressures, despite an increasing degree of slack in the economy. CPI inflation is projected to be 2.3% in two years’ time and 1.9% in three years.

The Committee judges that the risks around its modal CPI inflation projection are skewed to the upside over the first half of the forecast period, stemming from geopolitical factors. It now judges that the risks from domestic price and wage pressures are more evenly balanced, meaning that, unlike in previous forecasts, there is no difference between the MPC’s modal and mean projections at the two and three-year horizons.

Conditioned on the alternative assumption of constant interest rates at 5.25%, the path for CPI inflation is significantly lower than in the Committee’s modal projection conditioned on the declining path of market rates, falling below the 2% target from 2025 Q4 onwards.

The MPC’s remit is clear that the inflation target applies at all times, reflecting the primacy of price stability in the UK monetary policy framework. The framework recognises that there will be occasions when inflation will depart from the target as a result of shocks and disturbances. Monetary policy will ensure that CPI inflation returns to the 2% target sustainably in the medium term.

At this meeting, the Committee voted to maintain Bank Rate at 5.25%. Headline CPI inflation has fallen back relatively sharply. The restrictive stance of monetary policy is weighing on activity in the real economy and is leading to a looser labour market. In the Committee’s February forecast, the risks to inflation are more balanced. Although services price inflation and wage growth have fallen by somewhat more than expected, key indicators of inflation persistence remain elevated.

As a result, monetary policy will need to remain restrictive for sufficiently long to return inflation to the 2% target sustainably in the medium term in line with the MPC’s remit. The Committee has judged since last autumn that monetary policy needs to be restrictive for an extended period of time until the risk of inflation becoming embedded above the 2% target dissipates.

The MPC remains prepared to adjust monetary policy as warranted by economic data to return inflation to the 2% target sustainably. It will therefore continue to monitor closely indications of persistent inflationary pressures and resilience in the economy as a whole, including a range of measures of the underlying tightness of labour market conditions, wage growth and services price inflation. On that basis, the Committee will keep under review for how long Bank Rate should be maintained at its current level.

Minutes of the Monetary Policy Committee meeting ending on 31 January 2024

1: Before turning to its immediate policy decision, the Committee discussed: the international economy; monetary and financial conditions; demand and output; and supply, costs and prices. The latest data on these topics were set out in the accompanying February 2024 Monetary Policy Report.

2: Consumer price inflation across major advanced economies had declined by more than had been expected in the November Report, with continued easing of both goods and services price inflation. The Committee compared features of the disinflation seen across the United States, the euro area and the United Kingdom, and the risks around the inflation outlook. The Committee judged that the divergence seen across economies reflected differences in energy price dynamics and variation in the impact and timing of recent global shocks and their subsequent dissipation, alongside distinct profiles for spare capacity. Disinflation in core goods prices had been comparatively more pronounced so far in the United States because in the euro area and the United Kingdom the lag between falls in producer output price inflation and core consumer goods inflation had shown signs that it might have been longer than in previous cycles.

3: There had also been some differences, as well as commonalities, in the development of services price inflation and wage growth across these economies. Bank staff analysis suggested that the recent falls in services inflation across the three economies had been accounted for largely by declining non-labour input costs, including energy. Labour costs, by contrast, had remained elevated across countries, although there were some signs of easing emerging, particularly in the United States. To the extent that they were broadly comparable, measures of wage inflation had remained considerably higher in the United Kingdom than elsewhere.

4: In the United Kingdom, all of the respondents to the Bank’s latest Market Participants Survey (MaPS) expected Bank Rate to be left unchanged at this MPC meeting. They also all expected the next move in the Bank Rate to be downward. The median expected profile for Bank Rate from the MaPS implied a cumulative 100 basis point reduction in Bank Rate this year starting from June 2024, broadly in line with market pricing. Market contacts had suggested that disinflationary news in recent economic data outturns both in other jurisdictions and in the United Kingdom had been a significant factor in the downward moves in UK short-term rates in recent months. Similar downward moves in short-term rates had also occurred in other advanced economies over this period.

5: UK GDP growth had weakened in 2023, with this weakness particularly pronounced in market sector output. This reflected the significant tightening of monetary policy implemented since the end of 2021 to contain the persistence of second-round effects on inflation as well as continued weakness in potential supply growth. Cumulative GDP growth over 2023 as a whole had been materially weaker than expected at the time of the November Report, with the path for household consumption notably below expectations. Timelier indicators suggested that activity would edge up in 2024 Q1.

6: The Committee had completed its annual supply stocktake, as set out in Section 3 of the February Report, and judged that potential supply growth remained weak by historical standards. The MPC also now judged that the degree of excess demand had been a little higher over the recent past than had been assumed in the November Report, implying weaker supply growth in the past. At the same time, it had revised up slightly its view of potential supply growth in the future, although this was still expected to be weaker than the rates seen pre-Covid.

7: The Committee discussed the degree of persistence in wage growth and domestic price inflation. There had been downside news in headline CPI inflation relative to the November Report, accounted for by a combination of fuel, core goods and services prices. In absolute terms, services price inflation remained significantly elevated. There had been a common signal from a range of indicators that wage growth had eased somewhat recently, although it had remained significantly elevated overall. This downward trend had been most pronounced in the annual rate of growth of private sector regular average weekly earnings (AWE), although that had brought the AWE series more into line with other indicators.

8: The majority of this year’s wage setting processes would conclude in the next few months. A survey of firms conducted by the Bank’s Agents suggested that the average pay settlement in 2024 would be for a rise only slightly lower than in 2023, at 5.4%. It remained to be seen to what degree the falls in CPI inflation and short-term inflation expectations would influence this year’s wage setting, although this could also be influenced by a catch-up effect following the high rates of CPI inflation seen over the past couple of years. Evidence from the Agents suggested some possible upward pressures on wages from indirect effects of the increase in the National Living Wage. Intelligence from the Agents, however, also suggested that companies would not be able to pass on increased costs into prices as much as they had done in 2023.

The immediate policy decision

9: The MPC sets monetary policy to meet the 2% inflation target, and in a way that helps to sustain growth and employment.

10: In the MPC’s February Monetary Policy Report projections, UK GDP was expected to have been flat in 2023 Q4. Growth was expected to pick up gradually during the forecast period, in large part reflecting a waning drag from past increases in Bank Rate. In the medium term, the lower market-implied interest rate path, on which the forecast was conditioned, pushed up on GDP materially compared with the November projection.

11: The labour market had continued to ease, but had remained tight. In the February Report projections, the continuing relative weakness of demand, despite subdued supply growth by historical standards, led to a margin of economic slack emerging during the first half of the forecast period. Relative to November, the output gap projection had been pushed up by the boost to demand from the lower market path of interest rates. Equivalently, this implied that, if monetary policy were to follow the yield curve, then the stance of policy would be less restrictive than at the time of the November Report.

12: Twelve-month CPI inflation had remained above the 2% target. Inflation had fallen to 4.0% in December, below expectations in the November Report. The downside news had been broad-based, reflecting lower fuel, core goods and services price inflation. Although still elevated, wage growth had eased across a number of measures and was projected to decline further in coming quarters.

13: In the MPC’s latest most likely, or modal, projections, CPI inflation was expected to fall temporarily to the 2% target in 2024 Q2 before increasing again in Q3 and Q4. This profile of inflation over the second half of the year was accounted for by developments in the direct energy price contribution to 12-month inflation, which becomes less negative. Conditioned on a lower market-implied path for Bank Rate than had underpinned the November Report, CPI inflation was then projected to remain above the 2% target over nearly all of the remainder of the forecast period, owing to persistence in domestic inflationary pressures.

14: The Committee judged that the risks around the modal inflation projection were skewed to the upside over the first half of the forecast period, stemming from geopolitical factors. Risks from domestic price and wage pressures were now more evenly balanced, however. Taken together, this meant there was no difference between the MPC’s modal and mean projections at the two and three-year horizons.

15: The MPC judged that monetary policy would need to remain restrictive for sufficiently long to return inflation to the 2% target sustainably in the medium term, in line with the MPC’s remit. The Committee had judged since last autumn that monetary policy needed to be restrictive for an extended period of time until the risk of inflation becoming embedded above the 2% target dissipated.

16: Six members judged that maintaining Bank Rate at 5.25% was warranted at this meeting. Headline CPI inflation had fallen back relatively sharply. The restrictive stance of monetary policy was weighing on activity and was leading to a looser labour market. In the Committee’s February forecast, the risks to inflation were more balanced. Although services price inflation and wage growth had fallen by somewhat more than had been expected, key indicators of inflation persistence remained elevated. There were questions, on which further evidence would be required, about how entrenched this persistence would be, and therefore about how long the current level of Bank Rate would need to be maintained.

17: Two members preferred a 0.25 percentage point increase in Bank Rate, to 5.5%, at this meeting. Although headline inflation had fallen by more than had been expected, this was not necessarily informative about inflation persistence. Current indicators of economic activity had remained subdued, but real household incomes had continued to edge up, and forward-looking indicators of output had remained positive. The labour market was still relatively tight, consistent with a rise in the medium-term equilibrium rate of unemployment, and a range of indicators suggested that the pace of loosening had been slow. Measures of wage growth had moderated further but remained at rates above those consistent with the inflation target. Underlying services price inflation had slowed but remained elevated. These members continued to judge that there was evidence of more persistent inflationary pressures than included within the forecast. Financial conditions had eased since the MPC’s December meeting. An increase in Bank Rate at this meeting was necessary to address the risks of more deeply embedded inflation persistence and to return inflation to target sustainably in the medium term.

18: One member preferred a 0.25 percentage point reduction in Bank Rate at this meeting. For this member, the increments applied on the way up, together with lags in transmission, meant that Bank Rate needed to become less restrictive now. Waiting for lagging indicators of domestic relative price growth to fall sharply before reducing rates would come with a risk of overtightening. There might be potential upside risks from geopolitics. That said, consumer price inflation was already, and had been for some time, on a firm downward trajectory. Moreover, leading indicators, such as those from granular producer prices data, pointed to an easing in consumer prices. The outlook for demand remained weak, and less resilient than previously assumed, with vacancies falling more sharply than in some other advanced economies and consumption not having recovered to pre-pandemic levels. This further reduced the prospects of embedded persistence, shown in forward-looking indicators of domestic relative prices, such as monthly annualised rates of nominal pay growth and the Bank’s Agents’ surveys, and suggested lower pass-through of costs to prices.

19: The MPC remained prepared to adjust monetary policy as warranted by economic data to return inflation to the 2% target sustainably. It would, therefore, continue to monitor closely indications of persistent inflationary pressures and resilience in the economy as a whole, including a range of measures of the underlying tightness of labour market conditions, wage growth and services price inflation. On that basis, the Committee would keep under review for how long Bank Rate should be maintained at its current level.

20: The Chair invited the Committee to vote on the proposition that:

  • Bank Rate should be maintained at 5.25%.

21: Six members (Andrew Bailey, Sarah Breeden, Ben Broadbent, Megan Greene, Huw Pill and Dave Ramsden) voted in favour of the proposition. Three members voted against the proposition. Two members (Jonathan Haskel and Catherine L Mann) preferred to increase Bank Rate by 0.25 percentage points, to 5.5%. One member (Swati Dhingra) preferred to reduce Bank Rate by 0.25 percentage points, to 5%.

Operational considerations

22: On 31 January, the total stock of assets held for monetary policy purposes was £738.0 billion, comprising £737.6 billion of UK government bond purchases and £0.4 billion of sterling non‐financial investment‐grade corporate bond purchases.

23: The following members of the Committee were present:

Sam Beckett was present as the Treasury representative.

David Roberts was also present on 24 and 26 January, as an observer for the purpose of exercising oversight functions in his role as a member of the Bank’s Court of Directors.


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The Prudential Regulation Authority (PRA) fines HSBC £57,417,500 for failures in deposit protection identification and notification

News release

The PRA has fined HSBC Bank plc (HBEU) and HSBC UK Bank plc (HBUK) (together, the Firms) £57,417,500 for historic depositor protection failings arising from the Firms’ failures over many years to properly implement the requirements set out in the Depositor Protection Rules. These included the failure to accurately identify deposits that were eligible for Financial Services Compensation Scheme (FSCS) protection. The failings occurred for HBEU between 2015 and 2022, and for HBUK between 2018 and 2021. This fine, the second highest imposed by the PRA, reflects the seriousness of the failings.


The Depositor Protection Rules require firms to put in place adequate systems and controls, and governance, to ensure the integrity of critical information which the FSCS relies upon to make prompt payments to depositors in the event of a firm failure. HBEU’s depositor protection failings were so significant the PRA determined that it had materially undermined the firm’s readiness for resolution.

HBEU also failed to be duly open and cooperative with the PRA in not alerting the PRA over an approximately 15-month period about problems identified in the incorrect marking of accounts as “eligible” for FSCS protection. This was clearly information which the PRA would expect firms to share fully and in a timely way.

This meant the Firms breached Fundamental Rules 2 and 6, as well as Depositor Protection Rules 11, 12 and 14. HBEU was also found to have breached Depositor Protection Rule 50, and Fundamental Rules 7 and 8. This is the first PRA enforcement action in relation to Fundamental Rule 8, which states that firm must prepare for resolution so, if the need arises, it can be resolved in an orderly manner with a minimum disruption of critical services.

Sam Woods, Deputy Governor for Prudential Regulation and Chief Executive Officer of the PRA, said:

“The serious failings in this case go to the heart of the PRA’s safety and soundness objective. It is vital that all banks comply fully with our requirements around preparedness for resolution. HBEU fell far short of its obligations in this area, and failed to disclose its failings to us in a timely manner. These failures led to today’s action, including the significant fine.”

The Firms’ failings included:

  • The failure to assign clear ownership for the processes required under the Depositor Protection Rules; and
  • The failure to ensure that a senior manager, under the Senior Managers and Certification Regime, was allocated responsibility for these processes and the integrity of the information required under the Depositor Protection Rules.

HBEU’s failings further included:

  • Incorrectly marking 99% of its eligible beneficiary deposits as ‘ineligible’ for FSCS protection;
  • Providing an incorrect attestation to the PRA confirming its systems satisfied certain requirements of the Depositor Protection Rules; and
  • Failing to produce finalised versions of annual reports required to be signed by its board of directors that confirmed compliance with the requirements of the Depositor Protection Rules for multiple years.

The Firms’ cooperation throughout the investigation, including the early admission of certain rule breaches, resulted in a 15% reduction to the penalty. The Firms agreed to resolve the matter and therefore qualified for a further 30% reduction in the fine. Without these reductions, the fine imposed by the PRA would have been £96.5m. The PRA does not consider that the Firms’ breaches were deliberate or reckless.

The Bank of England publishes new enforcement policies

Following a period of consultation, the Bank of England (Bank) and the PRA today have also published Policy Statement PS1/24, which sets out the revised approach to enforcement for both PRA firms and financial market infrastructure firms. This includes revisions to the procedures of the Bank’s Enforcement Decision Making Committee (EDMC). The revised policies set out a new path for early cooperation and greater incentives for early admissions with the aim of speeding up investigations in appropriate cases. PS1/24 further sets out the PRA’s policies and procedures for making supervisory and non-enforcement statutory notice decisions. Today’s fine imposed by the PRA on HBEU and HBUK was under the PRA’s pre-existing penalty policy.

The Bank expects to consult on further amendments to its enforcement policies in 2024, reflecting the additional powers granted under the Financial Services and Markets Act 2023.


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