Interest Rate Hedging Products Mis-selling


The Mis-selling Project Team of a UK investment bank.

In summer 2012, the FCA identified failings in the way that some banks sold Interest Rate Hedging Products (IRHPs) and announced that the banks involved had agreed to review their sales of IRHPs made to certain customers since 2001. The IRHP review aims to put those customers which have been mis-sold products and have suffered loss back in the position in which they would have been had there not been a mis-sale. Since the beginning of the full review in May 2013, and with over 30,000 cases to review, the banks involved have taken on 2,800 staff to work through claims and have so far reviewed in excess of five million documents.

Issues that we helped identify

  • Dynamic FCA agreed standards of trade categorisation, regress off-setting policy and other boundaries of the project were defined through progression rather than at the outset
  • Client population priority shifts based on on-going complaints or live litigation
  • Electronic client file platform limitations on volume

How did we help our client?

  • Additional data sources suggested by us aided in identifying trends within client population so that boundaries could be tactically implemented throughout the review
  • Priority shifts were dealt with proactively and all elements were delivered within the agreed time frames
  • Efficiencies in client file collation and tracking with the Cyber Forensic team were developed by DRS to streamline provision and limit duplication

How did the project benefit our client?

  • Completion of specified project milestones on time or in advance of agreed deadlines
  • Our performance and expertise was such that specific consultants were sought to engage with new and on-going elements as the project developed
  • Contributed to design and project end to end

Project time and resource

We initially deployed five consultants, which was then extended to circa twenty, the majority of whom remain on-site and active on the project.

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