Fiftieth Report - Bounce Back Loans Scheme: Follow-up

Select Committee
Public Accounts Committee HC 951 27 April 2022
Report Status Government responded
Conclusions & Recommendations 26 items (17 recs)
Government Response (AI assessment · 24 of 26 classified)

Recommendations

15 results
3 Accepted
The Department has been complacent in preventing Scheme fraud and its prioritisation of ‘top tier’...
Recommendation
The Department has been complacent in preventing Scheme fraud and its prioritisation of ‘top tier’ fraudsters puts other government Schemes at risk. The risks that we identified at the outset of the Scheme have now materialised. The Department requested, and … Read more
Government Response Summary
The government agrees and states that in the event of another crisis similar in scale to the COVID-19 pandemic, the government would again need to consider the trade-offs between the generosity and speed of a loan guarantee scheme, and the consequent risks for value for money. There is now increased Fraud and Financial Crime resource in the Bank and the launch of the Public Sector Fraud Authority will further strengthen the ability of the government to manage and mitigate fraud risks.
HM Treasury
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4 Accepted
We are concerned that the Department is placing too much reliance on lenders to minimise...
Recommendation
We are concerned that the Department is placing too much reliance on lenders to minimise taxpayer losses without incentivising them to do so. When the Scheme launched the Department relied solely on lenders to prevent taxpayer losses by requiring them … Read more
Government Response Summary
The government agrees and says that the Bank assesses lenders’ compliance through its audit programme and can take remedial action and issue financial penalties to encourage lenders to identify and recover fraudulent loans. The FCA is working collaboratively with the Bank, the department and HM Treasury to find areas where regulatory powers and tools can add value.
HM Treasury
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5 Accepted
It is unacceptable that the Department has no plans to recover outstanding debt after lenders...
Recommendation
It is unacceptable that the Department has no plans to recover outstanding debt after lenders have pursued borrowers for up to 12 months. There is no minimum term that lenders are required to pursue borrowers for payments. Lenders are not … Read more
Government Response Summary
The government agrees with the recommendation to set out its strategy for collecting overdue payments after the lenders have completed their 12-month requirements and aims to implement it by Winter 2022. The long term BBLS counter fraud strategy will address the department’s strategy for enforcement and recoveries in cases of suspected fraud.
HM Treasury
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6 Accepted
The Scheme has distorted the Small and Medium Enterprise (SME) lending market in favour of...
Recommendation
The Scheme has distorted the Small and Medium Enterprise (SME) lending market in favour of the largest UK banks, which goes against the Bank’s objective of creating a diverse finance market for SMEs. The Scheme’s low interest rate made it … Read more
Government Response Summary
The government agrees with the Committee’s recommendation for the Bank to develop a strategy to mitigate the negative impact of the Scheme on the SME lending market and publish its findings in its next Small Business Finance Market report. The next iteration of the Small Business Finance Market report, expected in Q1 2023, will continue to report on the evolution of the small and medium-sized enterprises (SME) lending market. The Bank’s existing programmes continue to help challenger and specialist banks to make the SME banking market more diverse.
HM Treasury
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10 Accepted
The Scheme rules required commercial lenders to deliver loans and pursue recovery processes in line...
Recommendation
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 … Read more
Government Response Summary
The government agrees with the committee’s recommendation to improve lenders’ performance in managing loans and risks to the taxpayer by legal, regulatory and contractual incentives and states that ongoing management of the BBLS and associated financial risks remains one of the highest priorities for the department and the Bank. The Bank assesses lenders’ compliance through its ongoing lender audit and assurance programme and can take remedial action, ranging from creating an action plan with the lender’s management team through to cancellation of a guarantee.
HM Treasury
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16 Accepted
The Scheme has also made trade-offs in its response to countering fraud and the associated...
Recommendation
The Scheme has also made trade-offs in its response to countering fraud and the associated deterrent effects. The Department based its counter-fraud response on the 31 Qq 15, 16 32 Qq 74–75 33 Qq 74–75, 83 34 Correspondence from Catherine … Read more
Government Response Summary
The government agrees with the Committee’s recommendation that next time the Department launches an emergency business support scheme, it should be explicit on the trade-offs and level of fraud it is prepared to tolerate from the outset. It mentions the COVID-19 pandemic required an extraordinary response from government and the scheme's design would create a heightened vulnerability to fraud and there would be a significant risk of credit losses. There is now increased Fraud and Financial Crime resource in the Bank. Additionally, the launch of the Public Sector Fraud Authority this year will further strengthen the ability of the government to manage and mitigate fraud risks, deal with vulnerabilities, and overall increase its counter fraud capacity and capability.
HM Treasury
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17 Accepted
We asked the Department if it was confident that enough was being done to tackle...
Recommendation
We asked the Department if it was confident that enough was being done to tackle medium and bottom-tier fraud, to ensure there is a sufficient deterrent for smaller-scale fraud. It recognised that deterrence is “important” and was “on their minds”. … Read more
Government Response Summary
The government agrees with the recommendation to be explicit on the trade-offs and level of fraud it is prepared to tolerate from the outset next time the Department launches an emergency business support scheme. The BBLS was implemented under Ministerial Direction, and the exchange of letters that were published in June 2020 shows that these risks were acknowledged at the outset.
HM Treasury
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18 Accepted
We reported previously that the Department had no apparent plans to measure the Scheme’s long-term...
Recommendation
We reported previously that the Department had no apparent plans to measure the Scheme’s long-term impact, and no agreed performance measures.44 In its Treasury Minute response to our report, the Department gave a high-level summary of the Scheme’s evaluation plans … Read more
Government Response Summary
The government agrees with the recommendation to put in place a clear strategy to manage the long-term legacy of the Scheme and aims to implement it by Autumn 2022. They are formalizing a long-term strategy to counter fraud in the BBLS, building on work to date.
HM Treasury
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19 Accepted
We asked the Department whether it currently had the information that it needed to determine...
Recommendation
We asked the Department whether it currently had the information that it needed to determine whether the Scheme had been a success. The Department told us that it considered that the quality of information that it had about what was … Read more
Government Response Summary
The government agrees and will put in place a clear strategy to manage the long-term legacy of the Scheme within a month of the publication of its evaluation report, expected in Autumn 2022, including formalizing a strategy that will set out its long-term approach to counter fraud in the BBLS.
HM Treasury
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20 Accepted
Business survival rates are a key metric for measuring the Scheme’s impact.
Recommendation
Business survival rates are a key metric for measuring the Scheme’s impact. The Bank has commissioned an external evaluation study, which will report in stages over the next three years.50 We therefore asked the Department when we could expect to … Read more
Government Response Summary
The government agrees with the recommendation to put in place a clear strategy to manage the long-term legacy of the Scheme and aims to implement it by Autumn 2022. They are formalizing a long-term strategy to counter fraud in the BBLS, building on work to date.
HM Treasury
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22 Accepted
The NAO reported that there were seven accredited lenders when the Scheme launched in May...
Recommendation
The NAO reported that there were seven accredited lenders when the Scheme launched in May 2020, consisting of five main UK banks and two other banks.55 The Bank acknowledged that it took several months to accredit the additional 21 of … Read more
Government Response Summary
The government agrees with the recommendation for the Bank to develop a strategy to mitigate the negative impact of the Scheme on the SME lending market and publish its findings in its next Small Business Finance Market report, with a target implementation date of Spring 2023.
HM Treasury
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23 Accepted
The Bank recognised that it was “absolutely true that [the Scheme] had a distortive effect”...
Recommendation
The Bank recognised that it was “absolutely true that [the Scheme] had a distortive effect” but suggested that this was “diluting over time”.59 It confirmed that it still had an objective of encouraging diversity in lending markets. It explained that … Read more
Government Response Summary
The government agrees and will have the Bank develop a strategy to mitigate the negative impact of the Scheme on the SME lending market and publish its findings in its next Small Business Finance Market report, expected in Q1 2023. The Bank's existing programmes continue to help challenger and specialist banks to make the SME banking market more diverse.
HM Treasury
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24 Accepted
We highlighted previously that government needed to use the lessons learned from this Scheme to...
Recommendation
We highlighted previously that government needed to use the lessons learned from this Scheme to inform future schemes.62 We therefore asked the Department about examples of where it had identified and responded to lessons from the Scheme. The Department said … Read more
Government Response Summary
The government agrees with the recommendation to establish a strategy on how it intends to share lessons from the scheme and aims to implement it by Summer 2022. The department agreed to work in conjunction with HM Treasury and the Bank to produce a report covering lessons learned across the COVID-19 loan guarantee schemes.
HM Treasury
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25 Accepted
We were concerned that the Department should have identified these lessons when it supported businesses...
Recommendation
We were concerned that the Department should have identified these lessons when it supported businesses in the 2008 Financial Crisis. In 2010, the NAO’s report on the Department’s support to business during a recession concluded that the “impact [of the … Read more
Government Response Summary
The government agrees with the recommendation to establish a strategy on how it intends to share lessons from the scheme and aims to implement it by Summer 2022. The department agreed to work in conjunction with HM Treasury and the Bank to produce a report covering lessons learned across the COVID-19 loan guarantee schemes.
HM Treasury
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26 Accepted
We asked whether, with hindsight and more time, it would have been possible to design...
Recommendation
We asked whether, with hindsight and more time, it would have been possible to design a scheme that would have had significantly less exposure to fraud and error than 61 Q104; Public Accounts Committee, Covid-19: Bounce Back Loan Scheme, Thirty-Third … Read more
Government Response Summary
The government agrees with the recommendation to establish a strategy on how it intends to share lessons from the scheme and aims to implement it by Summer 2022. The department agreed to work in conjunction with HM Treasury and the Bank to produce a report covering lessons learned across the COVID-19 loan guarantee schemes.
HM Treasury
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8 Conclusion Accepted
The Department’s estimate of the credit loss within the Scheme is also uncertain, as there is no credit score data for borrowers because this was not a scheme requirement. Repayments will also be affected by future macroeconomic conditions which are themselves uncertain. In addition, because loans did not begin repayment …
Government Response Summary
The department has worked with the Bank to develop analytical and forward-looking expected credit loss models that are compliant with International Financial Reporting Standards (IFRS 9), which provide a sophisticated approach to forecasting expected credit losses across the COVID-19 loan guarantee schemes, utilising granular data from lenders and other sources.
11 Conclusion Accepted
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 …
Government Response Summary
The government agrees with the committee’s recommendation to improve lenders’ performance in managing loans and risks to the taxpayer by legal, regulatory and contractual incentives and states that ongoing management of the BBLS and associated financial risks remains one of the highest priorities for the department and the Bank. The Bank assesses lenders’ compliance through its ongoing lender audit and assurance programme and can take remedial action, ranging from creating an action plan with the lender’s management team through to cancellation of a guarantee.
12 Conclusion Accepted
The Scheme requires lenders to pursue borrowers for missed repayments for up to 12 months after the issue of a formal demand. The Department initially told us that lenders had to wait until after the 12 month period to make a claim on the guarantee.25 However, it wrote to us …
Government Response Summary
The government agrees with the committee’s recommendation to improve lenders’ performance in managing loans and risks to the taxpayer by legal, regulatory and contractual incentives and states that ongoing management of the BBLS and associated financial risks remains one of the highest priorities for the department and the Bank. The Bank assesses lenders’ compliance through its ongoing lender audit and assurance programme and can take remedial action, ranging from creating an action plan with the lender’s management team through to cancellation of a guarantee.
13 Conclusion Accepted
The NAO reported that the arrangements for pursuing borrowers offered limited commercial incentive for lenders to maximise recovery of overdue loans.28 In contrast, the Bank told us that it believed that lenders have strong legal, contractual and regulatory obligations to recover loans. This included oversight by the FCA and lender …
Government Response Summary
The government agrees with the committee’s recommendation to improve lenders’ performance in managing loans and risks to the taxpayer by legal, regulatory and contractual incentives and states that ongoing management of the BBLS and associated financial risks remains one of the highest priorities for the department and the Bank. The Bank assesses lenders’ compliance through its ongoing lender audit and assurance programme and can take remedial action, ranging from creating an action plan with the lender’s management team through to cancellation of a guarantee.
14 Conclusion Accepted
Almost 86,000 borrowers have been in arrears for more than 90 days as of 10 January 2022.34 We asked the Department what steps it was taking to ensure that its approach to recovering loans was as effective as possible and made best use of the data available to it. We …
Government Response Summary
The department, working with other government and non-governmental bodies, already collects an extensive amount of data resources for fraud risk assessment and identification analysis.
15 Conclusion Accepted
The Department and the Bank recognised that there was a trade-off between getting loans to businesses quickly by removing lender checks and slowing down the delivery of the loans by putting in place more counter-fraud measures. The Bank said that this would have had consequences for the economy, but argued …
Government Response Summary
The government agrees with the Committee’s recommendation that next time the Department launches an emergency business support scheme, it should be explicit on the trade-offs and level of fraud it is prepared to tolerate from the outset. It mentions the COVID-19 pandemic required an extraordinary response from government and the scheme's design would create a heightened vulnerability to fraud and there would be a significant risk of credit losses. There is now increased Fraud and Financial Crime resource in the Bank. Additionally, the launch of the Public Sector Fraud Authority this year will further strengthen the ability of the government to manage and mitigate fraud risks, deal with vulnerabilities, and overall increase its counter fraud capacity and capability.