Cranston Review

1. What is the Assurance Review?

On 7 May 2019 LBG announced the conclusion of the HBOS Reading Customer Review. The Review, overseen by Professor Russel Griggs OBE, was created to provide redress and compensation for those affected by criminal misconduct at the HBOS Impaired Assets Office for London and the South East, based in Reading.

Sir Ross will assess whether the process and application of the Customer Review methodology resulted in fair and reasonable compensation for customers. Sir Ross will prepare a report setting out his findings.

The Terms of Reference of the Cranston Review can be found here.

2. What is the objective of the Assurance Review?

The Review will assess whether:

• The methodology and process developed for the Customer Review has achieved the purpose of delivering fair and reasonable offers of compensation and has been consistently applied in accordance with established principles of Treating Customers Fairly.
• The judgements that have been made on individual customer cases are fair and reasonable, including in relation to the assessment of direct and consequential losses.
• The overall level of compensation to customers has been fair and reasonable when compared to the damages likely to have been available through a court process.
• Professor Griggs has exercised appropriate levels of independent challenge over customer outcomes, ensured that offers to customers have been reasonable and was able to properly perform his role.

3. What does this mean for you?

Sir Ross is not acting as an appeals process for those unhappy with the compensation offered by LBG. He will instead consider if the Customer Review provided fair and reasonable outcomes, and specifically whether the methodology provided a reasonable basis to deliver such fair outcomes and was applied consistently.

If you participated in the Customer Review at any stage, Sir Ross and his team will be seeking your views and experiences of the process. You should in due course receive a letter outlining what the Assurance Review would like to receive from you. Sir Ross is keen to receive the views and feedback from as many participants of the Customer Review as possible, and kindly requests that if you wish to make any submissions for his consideration or would like to meet with him, to please respond to his letter by Monday 8th July 2019.

We encourage customers to provide their own comments via email at info@CranstonReview.com, in writing, or alternatively by arranging a telephone call or meeting.

4. Does LBG direct or control the Assurance Review?

Whilst LBG was involved in conjunction with the FCA in establishing Sir Ross’s Terms of Reference for the Assurance Review, Sir Ross is wholly independent of any influence from LBG. It is vitally important that his review is open, rigorous, and fair, and that the LBG acts upon its recommendations (which it has committed to do).

5. What will the methodology of the Assurance Review be?

Sir Ross will be examining original documentation from LBG’s own files, as well as information provided to the Customer Review by customers, and documentation generated during the Customer Review. The Assurance Review will assess the Customer Review’s approach to:

1. Building a case file (including understanding LBG’s process for collecting documentation);
2. Assessing a case;
3. Calculating compensation (including consideration of direct losses, consequential losses and personal impacts);
4. Communicating with customers;
5. The level of disclosure (including the provision of information both to customers and to Professor Griggs, the explanation of outcomes and redress to customers, and whether customers were able and had the opportunity to challenge LBG’s view);
6. Supporting customers through the Review;
7. Seeking and acting upon additional information from customers;
8. Settlement agreements and whether the terms and conditions included within the agreements were fair and reasonable.

6. How long will the Assurance Review take?

The revised provisional expected completion date for the Assurance Review is mid-November 2019.

7. Will the results of the Assurance Review be published?

A report setting out Sir Ross’ findings will be made publicly available on this website when completed and also sent directly to relevant stakeholders.

8. Who will be included in the Assurance Review?

Any customers who at any stage participated in the Customer Review are encouraged to provide their views. This includes those who chose to opt out of the Review prior to receiving an offer of compensation, and those who did not accept the compensation offered. If you are not sure whether you are included in the scope of the Assurance Review, please contact us at info@CranstonReview.com.

The interview process will be an information gathering exercise. It is informal but it will be recorded.

9. Can I participate in the Assurance Review if I have signed a non-disclosure agreement (NDA) with LBG as part of a settlement under the Customer Review?

Although most participants in the Customer Review reached settlements and signed settlement agreements, there is no restriction on individuals disclosing information to the Assurance Review. Participation in the Assurance Review will also not compromise any compensation made, or pending, as part of a settlement.

10. Will there be funding available to cover legal and other third party costs associated with my participation in the Assurance Review?

Given the scope of the Assurance Review, Sir Ross does not envisage that customers will require legal support in providing their input, and legal submissions will not generally be appropriate, for the following reasons:

• Because the Assurance Review is a review of the Customer Review, and not an appeals process for those unhappy with the outcome offered by the Customer Review, the primary focus of any submissions should be the individual customers’ experiences of the Customer Review and how the Customer Review was conducted as a process.
• The Assurance Review will have access to all information provided by participants in the Customer Review. As such, there is no need for customers to repeat submissions or resubmit information/documents that they provided to the Customer Review.

However, Sir Ross recognises that there may be a small number of former Customer Review participants who may require some support from a third party advisor in formulating their input. If you feel that you require assistance to record your individual views and experiences of the Customer Review, Sir Ross has agreed with LBG that they will meet the reasonable costs of this assistance. Any such costs will only be met where they have been agreed in advance with LBG and are reasonable. LBG has agreed that ultimately the question of whether any costs are reasonable will be a matter for Sir Ross.

11. Will there be funding available to cover travel costs associated with my participation in the Assurance Review?

Sir Ross has agreed with LBG that they will cover reasonable travel costs for former Customer Review participants who wish to provide their input to the Assurance Review by way of a meeting with him. Again, this is subject to the costs being agreed in advance with LBG.

12. Who should I contact about costs?

If you wish to contact LBG about costs for providing your input to the Assurance Review, please contact Mark Pope on Mark.Pope@lloydsbanking.com or 0207 574 8861.