The Lloyds and Post Office Financial Scandals Compared

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The Lloyds and Post Office financial scandals are major national issues involving abuse of power, breach of trust, and devastating consequences for numerous individuals. The Post Office scandal, starting in 1999 with the faulty Horizon computer system, led to wrongful prosecutions of sub-postmasters, denial of wrongdoing, and a lack of proper compensation. On the other hand, the Lloyds Frauds scandal emerged after the 2008 banking crisis, with allegations of asset theft benefiting the bank's balance sheets and a cover-up of misconduct. Both cases highlight systemic failures and the need for accountability and justice.


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  1. THE LLOYDS FRAUDS MORE SERIOUS THAN THE POST OFFICE June 2021

  2. 2 The most serious financial scandal of modern times Post Office This is the true story of a national scandal. It is the story of how a venerable British institution abused its power, betrayed our trust and shattered the lives of hundreds of people . Nick Wallis The Great Post Office trial, BBC Sounds

  3. 3 The most serious financial scandal of modern times Lloyds This is the true story of another national scandal. It is the story of how a leading British bank abused its power, betrayed our trust and shattered the lives of thousands of people and how the Government and every arm of state have helped to cover up its wrongdoing. Lloyds Bank Victims Group

  4. 4 The most serious financial scandal of modern times The Post Office scandal 1 1999 - Fujitsu Horizon computer system introduced. Turned out to be faulty. However, Post Office embarked on a 14-year prosecution spree (2000 2013). 557 sub-postmasters wrongfully pursued by the Post Office for theft and false accounting. July 2013 - Post Office received the Clarke advice, which confirmed the existence of bugs in Horizon and indicated that its prosecutions were unsafe. Post Office continued with lying, denying and covering up. Parliament & MPs misled. Post Office defended their wrongful position in court and caused the sub-postmasters to incur legal costs of 46 mn. Nov 2018 - First trial. Further legal shenanigans. Following second trial in December 2019, Post Office settled but the settlement was a hollow victory with a limited apology and no admission of liability. Victims had to bear all their legal costs and have been left with minimal compensation. Sept 2020 Playing for more time, Government announced a non-statutory inquiry under Sir Wyn Williams. Government only made it statutory, after the convictions of 39 sub-postmasters were quashed by the Court of Appeal in April. Victims, who have been subjected to wrongdoing spanning nearly two decades, are still awaiting proper compensation.

  5. 5 The most serious financial scandal of modern times The Lloyds Frauds scandal 2 Following the 2008 banking crisis, the Government launched a modified version of the Asset Protection Scheme (APS) in November 2009. Designed by HM Treasury and the Head of Resolution at the Bank of England, Andrew Bailey, it authorised the two taxpayer- owned banks, Lloyds and Royal Bank of Scotland effectively to steal the assets of certain business customers to benefit their own balance sheets. RBS remained in the APS but Lloyds paid 2.5bn to opt out and ran its own parallel scheme. In January 2007, Lloyds had already turned its Business Support Unit (BSU) into a profit centre.2 Chancellor Darling, HM Treasury and Bailey went ahead. They knew they had crossed a major red line, so Bailey oversaw the cover up of all wrongdoing over the next decade and last year, he was appointed Governor of the Bank of England. The cover up remains firmly in place today.

  6. 1. SIMILARITIES

  7. 7 The most serious financial scandal of modern times 1. Involvement of HM Treasury Post Office Post Office Ltd is wholly owned by the Department of Business, Energy and Industrial Strategy (BEIS), which holds a special share in the company. BEIS has no day-to-day involvement in the running of the Post Office but monitors its performance via UK Government Investments Ltd (UKGI). It runs post offices as the name describes and is distinct from Royal Mail, which is the publicly listed company responsible for the collection and delivery of post via sorting offices. UKGI is owned by HM Treasury and acts as shareholder, representing government s interests in the stewardship of over twenty arms-length organisations and assets, ensuring their good governance, scrutinising their performance and looking to optimise their value and operational efficiency on behalf of the taxpayer. It does all of this in line with its Principles of Portfolio Governance, which set the standard for the governance of assets in the public sector . Post Office 2020 annual report.3 Under the Companies Act 2006, the duty of its board is to act in the interests of its shareholder, the Government, which has a representative on the board. However, the emphasis has been placed on saving the Post Office brand and preserving its reputation, regardless of the financial or human cost.

  8. 8 The most serious financial scandal of modern times 1. Involvement of HM Treasury Lloyds Oct 2008 Government bailed out Lloyds & RBS, using taxpayer money. The newly-created UK Finance & Investments (UKFI) took a 43.5% stake in Lloyds Banking Group. Nov 2009 The Chancellor, HM Treasury and the Bank of England under the direction of Andrew Bailey launched a modified version of the APS. Bailey then oversaw the subsequent cover up of bank wrongdoing and fraud, especially at the FCA. 2013-2017 UKFI sold all its shares in Lloyds, while at the same time, other arms of the State declined to investigate wrongdoing by Lloyds BSU & RBS Global Restructuring Group (GRG). This equated to securities fraud. In March 2018, UKFI was merged into UKGI. Nov 2018 Bailey and HM Treasury devised the Business Banking Resolution Service (BBRS) to seal away all bank wrongdoing permanently from the public gaze, ensure no accountability and award minimal compensation.4 Emphasis placed on preserving financial stability, regardless of the human cost and with no accountability.

  9. 9 The most serious financial scandal of modern times 2. Licence to mistreat Post Office The terms of business between the Post Office and its sub-postmasters was essentially, an extremely adverse contract.5 Treated as an account in law, it placed the onus on victims to demonstrate why their account did not balance and explain any shortfalls. They did not have the means or necessary information to do this. In 2018, the first Post Office trial concluded that key contract terms were so unfair as to be unenforceable.

  10. 10 The most serious financial scandal of modern times 2. Licence to mistreat Lloyds With regard to business lending, UK banks have no duty of care towards customers, are not required to conduct their business with due skill, care and diligence, or observe proper standards of market conduct. They do not have to pay due regard to the interests of their customers, treat them fairly and are not required to manage conflicts of interest fairly.6 Financial Conduct Authority (FCA) Principles of Business . For many years, the banks have strongly resisted introducing a duty of care and successive Governments and regulators have allowed them to do so. This has provided the banks with a licence to mistreat certain of their business customers.

  11. 11 The most serious financial scandal of modern times 3. Legal wrongdoing Post Office Uniquely, the Post Office has its own prosecutors, who operate outside of the Crown Prosecution Service (CPS). They brought charges of theft and false accounting against sub- postmasters over a 14-year period (2000-2013) and some of those convicted went to jail. 7 However, by failing to disclose the Clarke Advice which it received in July 2013, the Post Office breached its obligations to the court as a prosecutor. It knowingly covered up an estimated 736 miscarriages of justice. Possessed with unlimited funds, the Post Office then spent over 100mn defending its wrongful position, lying, denying and covering up (2013-2019). During this period, the chairman of the Post Office, Tim Parker was appointed chairman of HM Courts and Tribunal Service (HMCTS) in April 2018, a position which he continues to hold to the present day. Herbert Smith Freehills (HSF) was a leading firm responsible for defending the Post Office s wrongful legal stance but went on to act for the Post Office in the December 2019 settlement with the sub-postmasters. HSF was also put in charge of the Historic Shortfall (compensation) Scheme, which was launched in May 2020, payments from which will partly be met by Government. The aim throughout has been to limit the Post Office s liability to compensation. The Post Office had acted in such a way as to subvert the integrity of the criminal justice system and public confidence in it. In legal terms, this is known as second category abuse of process. Paul Marshall, Speech to The University of Law, 3rd June 2021. Post Office lawyers neglected their higher or prior duties to the court. I hope that some of them may end up in prison for perverting the course of justice . Paul Marshall.8

  12. 12 The most serious financial scandal of modern times 3. Legal wrongdoing Lloyds Lloyds Banking Group and its lawyers have subverted the integrity of the criminal justice system. They have corrupted, manipulated and ignored due process and the Rule of Law. They stand accused of the redaction, withholding, falsification and destruction of evidence; of fraudulent misrepresentation, perjury and other serious offences relating to perverting the course of justice. 9 Lloyds and its professional agents are accused of the systemic forgery of signatures on legal documents and of reliance, including in court, on deliberately invalid legal documentation. Since July 2019, 639 separate crime reports and 24 files of evidence, which contain these allegations, have been delivered to the National Crime Agency (NCA). Possessed with unlimited funds, Lloyds reportedly spent 850 mn in one year alone defending its wrongful position. Herbert Smith Freehills (HSF) has been central to Lloyds legal wrongdoing and has actively obstructed justice for the victims of the bank s frauds. The aim throughout has been to limit the bank s liability to compensation. The bank s lawyers neglected their higher or prior duties to the court. Complaint made last year to Solicitors Regulation Authority (SRA) regarding HSF 10 and we call for a criminal inquiry into their conduct.

  13. 13 The most serious financial scandal of modern times 4. Parliament misled & ignored Post Office Parliament has the supreme legal authority in the UK and parliamentary sovereignty is a key part of the British constitution. From 2014, MPs repeatedly raised questions about the Post Office scandal. In 2015, the Post Office told Parliament that it had received no evidence that the conviction of any applicant to its mediation scheme was unsafe. It was accused of lying to Parliament. Lately, the victims group, the Justice For Sub-postmasters Alliance (JFSA) has asked the Parliamentary Ombudsman to investigate the Government s role in the scandal, especially that of BEIS.

  14. 14 The most serious financial scandal of modern times 4. Parliament misled & ignored Lloyds Numerous debates in Parliament since 2009. Both in main house and Westminster Hall. All have been ignored. The Legislature has been treated with contempt by the Executive. Successive Economic Secretaries to HM Treasury (HMT) have led the Government s response with denial and stonewalling. The Treasury Select Committee has been packed with MPs, who have previously worked at HMT, to ensure that the Treasury s directions are strictly followed. Its tough questioning of those appearing before it has, on important occasions, been a sham.

  15. 15 The most serious financial scandal of modern times 5. Mis-use of mediation & inquiries Post Office Oct 2013 Sir Anthony Hooper appointed to chair working group overseeing a mediation process.11 Forensic accountants, Second Sight faced heavy resistance from Post Office, including refusal to release privileged information. March 2015 Post Office terminated engagement of Second Sight and the mediation process collapsed. Post Office accused of spending public money on a scheme, that they themselves have set out to sabotage . Sept 2020 Ten months after the victims effectively won in court, the Government agreed to a non-statutory inquiry under Sir Wyn Williams. It was only made statutory, following the quashing of 39 sub-postmasters criminal convictions in April.12

  16. 16 The most serious financial scandal of modern times 5. Mis-use of inquiries & mediation Lloyds / HBoS The appalling track record of the HBoS Reading fraud inquiries 13 Even after those immediately responsible were jailed in 2017, the Government and authorities have played for time by appointing a succession of inquiries see below. Not one of these was necessary. The position has now become so obscene that one of those jailed has been released before the victims of the fraud, which took place between 2003 and 2007, have been properly compensated. Griggs: First of four reviews was specifically authorised by the FCA. Rt. Hon Kevin Hollinrake MP accused Lloyds of using the review which is supposedly there to compensate the victims, to minimise payments and perpetuate the cover up. Cranston: A more carefully-crafted appraisal, which was also corrupted and manipulated by Lloyds and the FCA. Foskett: Being treated as public relations exercise by Lloyds. Dobbs: Has been inundated with accounts of Lloyds wrongdoing and fraud. Yet to report and major doubts now whether the full report will ever be made public (cf. Bailey s shenanigans in 2017 over releasing the section 166 report into RBS-GRG). Letting the truth out may be far too dangerous. Business Banking Resolution Scheme (BBRS) 4 Bank victims asked to trust a voluntary mediation scheme, under which banks including Lloyds are able, behind closed doors, to act as judge and jury over their own wrongdoing. They determined the criteria for eligibility, can decide which so-called boundary cases can be admitted and whether they are willing to pay the compensation amounts suggested. The ceiling for compensation for complaints prior to 1st April 2019 was set at 350,000, which will prove totally inadequate for many. Victims told that this scheme is all that is on offer . It would be difficult to construct a more unjust and biased process.

  17. 17 The most serious financial scandal of modern times 6. Corporate governance Post Office Post Office 2020 annual report: Our shareholder (BEIS) expects us to demonstrate high standards in corporate governance and we seek to comply with the requirements of the 2018 UK Corporate Governance Code and the Corporate Governance Code for Central Government Departments, where this is relevant to us as a limited company with a Government owner. The chairman of the Post Office, since 2015, has been Tim Parker. In April 2018, he was also appointed chairman of HM Courts and Tribunals Service (HMCTS), at the same time when the Post Office was misleading the courts and wrongfully dragging sub-postmasters through court processes at vast expense. The Post Office, including its Chairman, its Chief Executive, its Chief accounting officers, its Board and its Compliance Audit and Risk Committee share responsibility for this catastrophe . Paul Marshall, Lecture to the University of Law, 3rd June 2021.14 Lacking the integrity to resign, Parker remains the chairman of the Post Office and HMCTS.

  18. 18 The most serious financial scandal of modern times 6. Corporate governance Lloyds Horta-Os rio, former Chief Executive: was fully cognisant of Lloyds BSU s business model and the systemic fraud it deployed against thousands of viable SMEs. He was well aware of Lloyds manipulation of LIBOR and the repo rate and was involved with its cover up. He was very conscious of the HBoS Reading fraud and engaged in its subsequent dishonest concealment, together with the severe mistreatment of the whistleblower, Sally Masterton. He was also well aware of and complicit with Lloyds extensive legal wrongdoing, using heavyweight lawyers. Together with Lloyds former chairman, Lord Blackwell, Horta- Os rio was responsible for overseeing the cover up of the bank s extensive wrongdoing. Lord Blackwell, former Chairman: together with Horta-Os rio, he led the cover up and denials of serious banking fraud, including at successive AGMs. Juan Columb s, former Chief Operating Officer & present legal counsel, Cheetham: lied eight times in meeting with Thames Valley PCC, Anthony Stansfeld in 2017. Andrew Whittaker, former legal Counsel: withheld the major Turnbull report from Lloyds Chairman, Chief Executive and Chairman elect. It should be noted that all of the above individuals, with the exception of Cheetham, no longer work at Lloyds Bank. Indeed, they have all departed as goodleavers , notably Horta-Os rio who has received an honorary knighthood. 15 New Lloyds chairman, Robin Budenberg has advised companies on strategy and governance throughout his career and was responsible for oversight of these issues when managing the Government s investments in UK banks following the 2008 financial crisis. 16 Yet, he is continuing to cover up Lloyds extensive misconduct and criminal fraud, and use heavyweight lawyers to do so.

  19. 2. THE MAJOR DIFFERENCE THE EXTENT OF THE COVER UP

  20. 20 The most serious financial scandal of modern times Post Office Cover up Post Office covered up their wrongdoing, notably from 2013, when they received the Clarke Advice.17 They lied to Parliament 18 and Select Committees. Post Office breached its duties to the court as a prosecutor. The Post Office and its management were willing to expend vast sums of money, and to instruct the most expensive lawyers that money can buy, to prevent the truth coming out. Paul Marshall, Speech to University of Law, 3rd June 2021.19 The role of BEIS in the cover up of wrongdoing has yet to be determined.

  21. 21 The most serious financial scandal of modern times Lloyds Comprehensive cover up 20 Bailey & HM Treasury Senior Government ministers Home Secretary Financial Conduct Authority (FCA) Serious Fraud Office (SFO) National Crime Agency (NCA) City of London Police (CoLP) Regional police forces Solicitors Regulation Authority (SRA) Other bodies: FRC / ICAEW / RICS

  22. 22 The most serious financial scandal of modern times Lloyds cover up Bailey & HM Treasury During the 2008 banking crisis, the Head of Resolution at the Bank of England, Andrew Bailey and HM Treasury devised the Asset Protection Scheme (APS). This authorised the two taxpayer-owned banks to steal the assets of certain business customers. Beginning - The APS crossed a major red line in terms of legality. Nevertheless, Chancellor Darling, HM Treasury and Bailey went ahead. Lloyds paid to 2.5bn to opt out and reverted to its own scheme. Middle Since 2012, successive Chancellors & HM Treasury have been central to maintaining the cover up of the serious bank wrongdoing and criminality which followed. They ensured that the reform of the Financial Services Authority (FSA) into the FCA was largely a sham and that the regulator s remit was framed to allow it to act entirely as it chose or HM Treasury instructed. In 2016, Chancellor Osborne installed Bailey as chief executive of the FCA to ensure that the cover up was maintained. He was the perfect choice and was appointed famously withoutinterview . End ? Finally in 2018, Bailey and HM Treasury devised the Business Banking Resolution Service (BBRS), a deliberately biased, inadequate and merely voluntary scheme, whose purpose is to seal away banking misconduct for ever, ignore all criminality, refuse any accountability and award minimal compensation to victims.

  23. 23 The most serious financial scandal of modern times Lloyds cover up Senior ministers The Home Secretary In May 2014, the Home Secretary Theresa May received a copy of our c.100-page report Serious Corporate Fraud in the UK , which described how more than ten major instances of serious economic crime had not been properly investigated. Three months later, I received a reply from Rt. Hon Andrea Leadsom MP, then a Treasury minister, saying that no-one had any time to discuss the report. In June 2020, the Home Secretary Rt. Hon Priti Patel MP discussed our Lloyds Asset Theft Frauds report at length with the Police & Crime Commissioner for Thames Valley, Anthony Stansfeld. She received a hard copy of the 45-page report, together with overwhelming evidence of the systemic forgery of signatures and the use of deliberately invalid legal doumentation by banks, notably Lloyds. She did not reply to him for three months and then, it was largely dismissively. In May, the Home Secretary received the Operation Meadow files, which contain the evidence of more than sixty Lloyds victims, together with the Financial Matrix report, which describes the background to the Lloyds frauds. She bears the ultimate responsibility under the Police & Social Responsibility Act 2011, the Policing Protocol order no. 2744 21, when all other agencies have failed - and failed deliberately. She has yet to respond.

  24. 24 The most serious financial scandal of modern times Lloyds cover up Financial Conduct Authority (FCA) 22 The cover up of serious banking fraud, which has been overseen by former FCA chief executive Bailey and Chairman Randell has been unprecedented. There has been a catalogue of regulatory failure over HBoS Reading, RBS Global Restructuring Group (GRG), Lloyds BSU and numerous others. The FCA has conspired, sometimes with other government agencies, to frustrate due and proper process over the banks signature forgeries, LIBOR investigations and IRHP redress among many. In August 2020, the FCA under chairman Randell announced moves to limit the compensation payable to victims of its own regulatory failure. However, its own independent complaints commissioner described these as an explicit fettering of compensation for direct financial loss . Under Bailey and Randell, the UK s foremost financial regulator has recorded new lows in terms of standards and this is impacting the reputation of the City of London as a global financial centre. Having previously directed the cover up of serious banking fraud, Bailey is now disgracing the Governorship of the Bank of England and must resign, together with Randell and others. Our country cannot afford to have people, who lack integrity, being placed in the highest positions of authority.

  25. 25 The most serious financial scandal of modern times Lloyds cover up Serious Fraud Office (SFO) 23 The conspicuous shortcomings in the UK s investigation of major economic crime have been described in the report entitled High Level Fraud by the former Police & Crime Commissioner for Thames Valley, Anthony Stansfeld. 24 The SFO deliberately failed in its investigations into the manipulation of LIBOR. It closed its investigation into Lloyds manipulation of the widely-used interest rate in July 2018 and closed its entire seven-year inquiry in October 2019, conveniently two months ahead of Bailey being announced as the next Governor of the Bank of England (BoE). The BBC had previously obtained evidence that the BoE had been involved in the manipulation of the internationally recognised benchmark. From 2019, the SFO colluded with the FCA to frustrate the timely and proper investigation by the NCA of the systemic forgery of signatures by major banks, notably Lloyds and RBS. The SFO also failed to investigate allegations of serious wrongdoing by, among others, Lloyds Recoveries Bristol and its fraudulent associate, UK Acorn Finance 25. In the latter connection, it gave the excuse that Avon & Somerset Police had previously investigated and found no evidence of wrongdoing. 26 The SFO has been deliberately under-funded for many years, while its fines simply revert to HM Treasury. The SFO needs to be established as a separate entity, completely free from Government influence and independently funded from bank and other fines.

  26. 26 The most serious financial scandal of modern times Lloyds cover up National Crime Agency (NCA) 27 The NCA s role is to investigate serious organised crime but in two recent instances, it is conspicuously and intentionally failing to do so. The NCA has received 24 files and 639 separate reports of signature forgery by banks, together with their use of deliberately invalid documentation in court. For nineteen months, it refused to investigate, even turning down the Treasury Select Committee s requests three times in writing. Then finally, it has investigated collusion between banks to forge signatures, when this was never the accusation. The accusation is that individual banks have forged signatures on an industrial scale. In the US, such activity was condemned as an attack on the integrity of the court system but in the UK, the NCA is attempting to cover it up. This is blatantly and deeply corrupt. 28 In March, the NCA ended its investigation into further aspects of the HBoS Reading fraud, claiming that it could find no evidence of criminality, when instances of criminal wrongdoing are everywhere to be seen. The Director-Generals of both the NCA, Lynne Owens and the National Economic Crime Centre (NECC), Graeme Biggar must step down because they have brought the UK s leading crime fighting agency into serious disrepute. Why should ordinary citizens respect the Rule of Law, when senior figures in authority do not ?

  27. 27 The most serious financial scandal of modern times Lloyds cover up City of London Police (CoLP) CoLP controls the investigation of economic crime throughout the UK and is not accountable to Parliament but to the Guildhall in the City of London. Both facts are not widely known. The force is responsible for Action Fraud, the first agency to which victims of fraud are referred and whose comprehensive failings have long been highlighted in the national press. CoLP also maintains the UK s database for economic crime, the National Fraud Intelligence Bureau (NFIB). The failure of regional police authorities to address economic crime may partly be the result of insufficient specialist manpower and inadequate funding but it may also have been the result of deliberate policy and central direction, including from CoLP. The systemic failure of the UK authorities to address economic crime is now attracting international disrepute. Certain individuals have occupied key positions of authority and look to have been responsible for the deliberate failure to investigate major instances of economic crime, especially serious banking fraud. 29 The US has referred to Britain as a higher risk jurisdiction 30, its polite term for a dirty little country. The emphasis in the UK remains on cover up, rather than clean up. Such an approach is unsustainable.

  28. 28 The most serious financial scandal of modern times Lloyds cover up Regional police forces 31 At least ten regional police authorities have refused to investigate serious banking fraud. The most notorious example has been provided by Avon & Somerset Police (A&SP), which for over a decade has declined to investigate widespread fraud involving Lloyds Recoveries, Bristol and its fraudulent associates. More recently, complaints about A&SP s refusal to investigate were elevated to the Independent Office for Police Conduct (IOPC) but in common with the latter s much-publicised failure over Operation Midland, the IOPC merely referred the complaint back to A&SP. An official request for HM Inspectorate of Constabulary (HMIC) to launch an investigation into the matter is presently being blocked by the Minister for Policing, Rt. Hon Kit Malthouse MP. Policing is now la carte - to be conducted, when it suits the authorities but not, when it doesn t. 32

  29. 29 The most serious financial scandal of modern times Lloyds cover up Solicitors Regulation Authority (SRA) 33 The SRA has deliberately failed to take any meaningful action against large and medium-sized firms of solicitors or individual solicitors, who act or have acted for the major banks. In July 2020, the All Party Parliamentary Group (APPG) for Fair Business Banking lodged a complaint with the SRA regarding Herbert Smith Freehills entitled The Lloyds Banking Group Reading Fraud undermining confidence in the legal profession . However, no action has been taken against the firm. In 2008/2010, the SRA also failed to take any action following an investigation into the Bristol-based solicitors, Burges Salmon, which was used by Lloyds Bristol Recoveries. This encompassed its senior partner, together with 61 staff and partners. Burges Salmon have had demonstrable links to the HBoS Reading fraud. In 2014/16, a second investigation into a solicitor, formerly of Burges Salmon and had acted previously for Lloyds Recoveries Bristol and UK Acorn Finance was so engineered that ultimately, no action was taken against him or his firm. A complaint of serious professional misconduct regarding TLT, the Bristol-firm of solicitors presently used by Lloyds Banking Group, has also been ignored by the SRA and no action taken. Meanwhile, in July 2020, the SRA announced plans to reduce the compensation payable to clients, who have suffered loss due to a solicitor s dishonesty or failure to account for client money. The regulator is seeking to reduce this from 2mn to 500,000 but has been opposed by the Legal Services Board, which recognises the deliberate injustice, which this move represents. 34

  30. 30 The most serious financial scandal of modern times Lloyds cover up FRC / ICAEW / RICS In December 2018, an independent review under Sir John Kingman concluded that the Financial Reporting Council (FRC), the audit and governance regulator, was not fit for purpose. However, despite his recommendation of its replacement with the Audit, Governance & Regulatory Authority (ARGA) and subsequent scandals, more than two years later nothing has been done. 35 The Institute of Chartered Accountants of England & Wales (ICAEW) has refused repeated requests to read a detailed barrister s opinion regarding criminal wrongdoing by Price Waterhouse Coopers in a major case of Lloyds impropriety and fraud. Our evidence suggest that this is not an isolated example of major wrongdoing by the firm. KPMG was heavily implicated in serious wrongdoing in the Turnbull report, which involved HBoS senior management and a 40bn hole in its 2007 accounts, which the accounting firm overlooked. 36 In 2013, John Griffith-Jones, senior partner of KPMG (UK) at the time of the failed HBoS audit, was appointed as the first chairman of the supposedly reformed Financial Conduct Authority (FCA). The Royal Institution of Chartered Surveyors (RICS) deliberately failed to investigate complaints of serious wrongdoing by Lloyds unlicenced and invalidly appointed LPA receivers. It is clear that like SRA and ICAEW, it intends to act as the trade body for its profession and protect its members against such accusations.

  31. 3. THE REAL CASUALTIES

  32. 32 The most serious financial scandal of modern times 1. Victims The victims, whose lives have been wrecked by banking misconduct and fraud, dating back more than a decade. They are currently being actively denied justice by: The Home Secretary National Crime Agency Avon & Somerset Police BBRS and of course, Lloyds Bank. 37 The new Lloyds chairman, Robin Budenberg received our 94-page report, The Lloyds Omnibus of press releases at a meeting on 17th January. He then referred everything to their lawyers and is continuing to play for time.

  33. 33 The most serious financial scandal of modern times 2. The Rule of Law 38 The Rule of Law is a fundamental principle of our democracy, and at its heart, lies the equality of all before the law. However, our Government regards the Rule of Law as something, which can be overidden and ignored when it suits or manipulated to advantage. The Law is now used to control and constrain the mass of the population but financial elites are more confident than ever that laws and oversight apply to them in name only. Heavyweight firms of lawyers engaged by the Post Office and Lloyds have used their clients seemingly unlimited resources to abuse the law and due process.

  34. 34 The most serious financial scandal of modern times 3. Our country and its reputation 39 Our international reputation is falling sharply, with the UK now regarded by Europe and the US as untrustworthy. The EU is withholding agreement with regard to the City of London over equivalence because it no longer trusts us. It is absolutely right not to do so. The UK s disregard for international law is continuing to highlighted with respect to the Northern Ireland protocol. However, this is just one aspect of a considerably more serious malaise. Our regulatory and prosecutorial systems are rotten. Their comprehensive failures have also been covered up by the continued silence of opposition parties in Parliament and a largely complicit press & media, which depends heavily on the major banks for advertising. With an 80 seat majority, the Government believes that it can maintain the cover up, that the wider public do not understand or even if they do, they will not care. Clearly, this attitude is deeply improper. The greatest casualty in all this is our country and its reputation. If no-one cares about this any longer, it will be time to say Goodnight .

  35. 35 The most serious financial scandal of modern times Our Aims Compensation for Lloyds victims. A limited set of prosecutions to ensure an immediate improvement in professional standards. Comprehensive reform 40 everyone knows what needs to be done. We cannot continue as we are.

  36. 36 The most serious financial scandal of modern times References (1) (w) available on our website www.lloydsbankassetfrauds.com 1. Sources: BBC Sounds https://www.bbc.co.uk/sounds/series/m000jf7j; also Paul Marshall Scandal at the Post Office , speech to University of Law, 3rd June 2021 https://www.postofficetrial.com/2021/06/marshall-spells-it-out- speech-to.html 2. Lloyds Omnibus edition of press releases (Dec 2020): section 15. Lloyds Business Support turned into profit centre. (w) 3. Post Office 2020 annual report, page 14 https://corporate.postoffice.co.uk/media/48552/pol-combined-ara- 1920_2020-final-signed-incl-pwc.pdf 4. Lloyds Omnibus, section 40. BBRS deliberately deceitful, intentionally unjust. (w) 5. Paul Marshall, speech to University of Law, 3rd June, page 8. 6. Treasury Select Committee report on SME Finance, October 2018, pp. 23-24. 7. The Great Post Office Trial, episode 5. 8. Paul Marshall, speech, page 3. 9. Lloyds Omnibus, section 4 Lloyds corruption of the Rule of Law; section 17 Lloyds abuse of legal process; section 18 Lloyds industrial forgery of signatures; section 20 Lloyds Land Registry fraud; section 21 Lloyds insolvency and false bankruptcy; section 26 Lloyds Banking Group untouchable and above the law. (w) 10. All Party Parliamentary Group (APPG) on fair business banking submission to Solicitors Regulation Authority re Herbert Smith Freehills The Lloyds Banking Group Reading Fraud undermining confidence in the legal profession , July 2020. 11. The Great Post Office trial, episodes 5 & 6; Paul Marshall, speech, pp. 10-11.

  37. 37 The most serious financial scandal of modern times References (2) 12. https://www.theguardian.com/uk-news/2021/apr/23/court-clears-39-post-office-staff-convicted-due-to-corrupt-data 13. Lloyds Omnibus: section 12 HBoS Reading three unnecessary reviews; section 13 How the Cranston review was corrupted; section 14 Dobbs report delayed the corrupt farce over HBoS Reading marches on; also under Additional Releases: Lloyds update over HBoS Reading utterly disgraceful. (w) 14. Paul Marshall, speech, page 3. 15. Additional Releases: The knighting of Horta-Osorio the UK in deep water. (w) 16. https://www.thecrownestate.co.uk/en-gb/about-us/our-people/the-board/robin-budenberg/ 17. Paul Marshall, speech, especially pp. 9 -10. 18. Ibid, page 11. 19. Ibid, page 2. 20. Lloyds Asset Theft Fraud report provided to the Home Secretary, Rt. Hon Priti Patel MP in June 2020 table, page 12 Protecting the centre . (w) 21. https://www.legislation.gov.uk/uksi/2011/2744/made 22. The FCA s leadership must resign, May 2021 (w) 23. Lloyds Omnibus, section 33 SFO not serious about bank fraud & not fit for purpose. (w) 24. High Level Fraud , report by the former Police & Crime Comissioner for Thames Valley, Anthony Stansfeld. (w) 25. See Serious Corporate Fraud in the UK , May 2014 report delivered to the Home Secretary, Rt. Hon Theresa May MP - available on request. 26. Letter of SFO Director David Green to Rt. Hon Bill Wiggin MP, 20th September 2016. 27. Lloyds Omnibus, section 18 Lloyds industrial forgery of signatures; section 19 Britain s NCA playing fast and loose with the Rule of Law. (w) 28. Additional Releases: Lloyds & the deliberate denial of justice. (w) 29. Lloyds Asset Theft Fraud report, appendix 5: The Gatekeepers , pp. 30-31. (w) 30. https://www.ftadviser.com/regulation/2020/09/23/mps-question-regulators-after-money-laundering-leak/

  38. 38 The most serious financial scandal of modern times References (3) 31. Lloyds Omnibus, section 35 Regional police authorities refusal to investigate Lloyds frauds. (w) 32. Additional Releases: Policing when it suits but not when it doesn t. (w) 33. Lloyds Omnibus, section 34 SRA s failure to investigate certain fraudulent solicitors. (w) 34. Lloyds Omnibus, section 37 Look out, victims, you are being rolled over, page 80, paragraph 4. (w) 35. Lloyds Omnibus, section 31 Financial Reporting Council s role in cover up. (w) 36. Crash, Bank, Wallop Memoirs of the HBoS whistleblower by Paul Moore, head of regulatory risk at HBoS, New Wilberforce Media. 37. Additional Releases: Lloyds & the deliberate denial of justice. (w) 38. The Rule of Law why it matters and how it is being corrupted. (w) 39. Lloyds Omnibus epilogue: Ashamed to be British, pp. 93 94. (w) 40. Lloyds Omnibus sections 41 & 42: suggested reforms. (w)

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