SME banking 2002 behavioural undertakings: report on banks’ compliance audit 2023
2023 audit report into whether 8 leading UK banks are complying with undertakings they gave not to bundle loans and accounts.
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In 2002, a number of banks agreed that they would no longer (except for in specific circumstances) make a small and medium-sized enterprise (SME) customer open or maintain a business current account in order to get a business loan. This practice is commonly known as ‘bundling’ and was prevented by behavioural undertakings.
In 2014, 8 banks agreed to submit annual audit reports of their systems and procedures to the Competition and Markets Authority (CMA). The CMA reviews these and reports on its findings each year in the reports on compliance above.
The following 8 banks are currently subject to the bundling prohibition:
- AIB Group (UK) plc (known as AIB NI in this report, and previously known as First Trust)
- Bank of Ireland UK plc
- Barclays Bank plc and Barclays Bank UK plc (together, Barclays)
- Clydesdale Bank plc’s SME Business and Branches in Scotland branded as Virgin Money (Clydesdale)
- HSBC UK Bank plc (HBUK). HSBC’s non-ringfenced bank HSBC Bank plc (HBEU) remains subject to the Undertakings but was released from the 2014 Agreement during 2023
- certain group companies of Lloyds Banking Group plc, formed from the merger of HBOS plc and Lloyds TSB Bank plc (Lloyds)
- Northern Bank Limited (Danske)
- NatWest Group plc (NatWest) (formerly the Royal Bank of Scotland Group plc (RBS)) which includes Ulster Bank Limited (Ulster Bank) in Northern Ireland