FCA public censure: every action on record

On 9 March 2012 the FSA issued a Final Notice publicly censuring Bank of Scotland plc for breaching Principle 3 of the FSA’s Principles for Business during January 2006 to December 2008. Principle 3 requires firms to take reasonable care to organise and control their affairs responsibly and effectively, with adequate risk‑management systems. The FSA found the bank’s Corporate Banking Division pursued an aggressive growth strategy in high‑risk, sub‑investment grade lending without taking reasonable steps to assess, manage or mitigate the risks, maintained weak controls and oversight as markets deteriorated in 2007, and between April and December 2008 failed to take reasonable care over high value transactions showing signs of stress. The FSA said a financial penalty would have been merited and substantial but, in the exceptional circumstances of the case, decided not to impose one and issued a public censure instead.