Introduction

Michael Grimwade

“The farther back you can look, the farther forward you are likely to see.”

Winston Churchill, twice British Prime Minister during the 20th century

I joined Lloyds TSB as Wholesale & International Operational Risk Director in May 2004. This was just nine months after the firm had received what was then a record fine of £1.9 million from the Financial Services Authority for the mis-sale of its Extra Income and Growth Plan, or “precipice bonds”, as the tabloids more pejoratively called them.11Lloyds TSB’s £1.9 million FSA fine relating its “Extra Income and Growth Plan”, September 24, 2003. Lloyds TSB had also agreed to pay a further £98 million in compensation regarding 22,500 sales of this product. A shocking event for the firm at the time.

Only a dozen years later, however, the new record fine22This fine was levied by the Financial Conduct Authority, one of the FSA’s two successors. in the UK (for Barclays this time) was 150 times larger.33Barclays’ £284.4 million FCA fine relating to misconduct in the FX markets, May 20, 2015. Separately, as at the end of 2015, an enlarged Lloyds Banking Group had established a provision for PPI compensation that was 160 times44Lloyds

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