Although the Department referred to lenders as the “arms and legs” of the Scheme, none of the witnesses could tell us how much lenders are spending on counter-fraud activities. The FCA said, for example, that lenders had “scaled up quite significantly”, but it could not tell us when they had done so and it recognised that it still needed to discuss with lenders the size and scale of resources in place. It had issued some guidance to lenders; as the NAO reported, it wrote to lenders in July 2021 to remind them of their 16 Qq 17, 55; C&AG’s Report, Appendix One, para 12 17 Qq 19, 21, 53; C&AG’s Report, Appendix One, para 6 18 Qq 17, 53; C&AG’s Report, Appendix One, para 7 19 C&AG’s Report, para 2.29 20 Correspondence from Catherine Lewis La Torre, Chief Executive, British Business Bank, Re Bounce Back Loans, 27 January 2022, published 31 January 2022 21 Qq 28, 55, 57, 62, 92; C&AG’s Report, para 2.27 22 Qq 28, 62 12 Bounce Back Loans Scheme: Follow-up obligations to report fraud and have an adequate level of resources.23 The Bank explained that lenders were not keen on doing a detailed cost allocation exercise to identify the level of resources, but lenders were reporting their activity to a lender forum for sharing best practice. In its letter to us after our evidence session, the Bank told us that lenders had so far identified 1.4% of the loans by value (£631.5 million) as having suspected fraud, but it expected this number to increase.24