The Scheme rules required commercial lenders to deliver loans and pursue recovery processes in line with their existing business-as-usual standards. The Department and HM Treasury stated that the majority of recoveries and counter-fraud efforts comes from lenders. The Department told us that the commercial banking sector was the “best of the best” at managing the Scheme’s recovery process in line with equivalent standard loans, with the Bank adding that lenders have “decades, if not centuries” of related expertise.21 The Department had therefore concluded that it would not make sense for it to recover loans because lenders undertook that role. It explained that the Department, therefore spends a “tiny fraction” of budget on loan recovery compared with the resources among lenders and law enforcement agencies. Instead, the Department and the Bank told us that it saw its role to define the minimum standards and make sure the overall system is working well.22