royal bank of scotland form ccp1 - texto...

ROYAL BANK OF SCOTLAND Form CCP1

© Conduct Costs Project 2012-2014

1

Name of bank / group

Date Event description

Full name of legal entity involved (and place of incorporation and principal place of business)

Source of information

Code (See CCP2)

Jurisdiction where event occurred (e.g., where fine imposed)

Name of regulator or other authority

Amount1 [GBP M]

Any specific observations of compiler

2009

RBS 31/03/2009

Fine paid. RBS GC failed to report transactions & correct trade execution time in TRACE-eligible securities to TRACE within 15 minutes of the execution time, showing a pattern or practice of late reporting without exceptional circumstances as well as failed to show the correct execution time on brokerage order memoranda.

RBS Greenwich Capital incorp in CT, USA w business in Greenwich, CT

Disciplinary and Other FINRA Actions Reported for March 2009

DIS, CON, OPE

DC, USA FINRA 0.010

—

Total (CC 2009): GBP 0.01 M

1 These figures should be read subject to the points made under "Notes on the Interpretation of the Figures".



2





Code (See CCP2)



Amount1 [GBP M]


2010

RBS 30/03/2010

Settlement paid. Disclosure/exchange of commercially sensitive information/future pricing (re loan products to large professional services firms) to colleagues at competitor, hence breach of competition law.

The Royal Bank of Scotland Plc (RBS) Group Secretariat RBS incorp in UK w business in Edinburgh, Scotland

"RBS agrees to pay £28.5 million penalty for disclosing pricing information to competitor" , www.oft.gov.uk/ RBS Group, Sustainability Report 2010 , p34

DIS, CON

UK FSA, OFT 28.590

—

RBS 31/07/2010

Fine paid. RBSS failed to report the correct time of trade execution for transactions in TRACE-eligible securities to TRACE, and failed to report these transactions

RBS Securities Inc incorp in CT, USA w business in Stamford, CT

Disciplinary and Other FINRA Actions Reported for July 2010

DIS, CON, OPE

DC, USA FINRA 0.006

—



3





Code (See CCP2)



Amount1 [GBP M]


within 15 minutes of the execution time. The findings stated that the firm failed to show the correct execution time on brokerage order memoranda.

RBS 02/08/2010

Settlement paid. RBS had not apt risk-sensitive policies/ procedures re: (1) customer due diligence/monitoring; (2) internal control; (3) monitoring / management of compliance/ communication of, such policies and procedures, to prevent money laundering (list of financial


Financial Services Authority, Decision Notice, 2 August 2010, p1-3

AML, SAN, CON, DIS

UK FSA 5.600

—



4





Code (See CCP2)



Amount1 [GBP M]


sanctions targets/HMT list). Breach of regulation 42 re Money Laundering and breach of regulation 20(1) between 15 December 2007 and 31 December 2008.

RBS 03/12/2010

Fine paid. ABN AMRO provided unsuitable advice on insurance policies to clients wishing to enter into credit protection insurance policies, during the period from 1 January 2009 to 31 July 2009, providing

ABN AMRO NV incorp in NLD w business in Amsterdam, NLD

"AFM has imposed an administrative fine on ABN AMRO N.V. for unsuitable advice on insurance policies", www.afm.nl

PPI NLD AFM 0.025

—



5





Code (See CCP2)



Amount1 [GBP M]


consumers with cover in the event of loss of income as a result of occupational disability or death. ABN AMRO has not taken into account sufficient information and interest of clients in 16 cases. ABN AMRO thus acted in breach of Section 4:23 (1, a and b) of the Financial Supervision Act.

Total (CC 2010): GBP 34.22 M



6





Code (See CCP2)



Amount1 [GBP M]


2011

RBS 11/01/2011

Settlement paid. RBS mis-handled complaints re their UK Retail bank branch network (“RBS UK Retail”) and mis-dealt with escalated complaints arising from the branch network. RBS UK Retail failed to: (1) take apt care to organise and control its affairs responsibly and effectively, with apt risk management systems; and (2) pay apt attention

Royal Bank of Scotland Plc incorp in UK w business in London, England

Financial Services Authority, Final Notice, 11 January 2011, p1-3

CON UK FSA 2.800

—



7





Code (See CCP2)



Amount1 [GBP M]


to interests of customers and treat them fairly. Breach of Principle 3 (Management and control) and Principle 6 (Customers’ interests) and Rules in the Dispute Resolution between 1 December 2008 and 25 March 2010.



8





Code (See CCP2)



Amount1 [GBP M]


RBS 07/11/2011

Settlement paid.Breached FSA Principle 9.Mis-selling (of AIG Life Premier Access Bond and Premier Bond, EnhancedVariable Rate Fund) and failed compliance review thereof.Gave unreasonable advice/market updates; used inapt sales process/ documents/ training/ compliance review/ disclosure; wrong risk/diversification assessment; created conflict of interest; misrepresented product.

Coutts & Coincorp in UKw business in London, England

"Coutts fined £6.3m for failings relating to its sale of an AIG fund", ww.fsa.gov.uk/library/communication/Financial Services Authority, Final Notice, 07 November 2011

MIS, CON

UK FSA 6.300

—



9





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2011 PPI mis-selling redress Provisions Utilised in 2011.


RBS Group, Annual Report and Accounts 2011, 22 February 2012 + Notes on the consolidated accounts, Note 22, doc p377

PPI UK FSA, FOS 320.000

PPI provisions 01.01.11: GBP 0. Transfer accruals and other liabilities: GBP 215M. New PPI provisions in 2011: GBP 850M. PPI provisions 31.12.11: GBP 745M. PPI redress paid during 2011: GBP 320M (actual payment, not a provision).

Total (CC 2011): GBP 329.10 M



10





Code (See CCP2)



Amount1 [GBP M]


2012

RBS 23/03/2012

Settlement paid. Breached FSA Principle 3. Failed to establish/maintain effective AML systems & controls; due diligence, scrutiny, challenge; consistent monitor; regular review re high-risk customers/PEPs.

Coutts & Co incorp in UK w business in London, England

Financial Services Authority, Final Notice, 12 March 2012 RBS Group, Sustainability Report 2012, p49

AML, CON

UK FSA 8.750

—



11





Code (See CCP2)



Amount1 [GBP M]


RBS 14/11/2012

Settlement paid. Liquidity contraventions: failed to apply haircuts; failed to establish/ maintain internal controls for liquidity risk mgmt; failed to notify Central Bank immediately of these contraventions. Capital requirements contraventions: failed to hold own funds in excess of min level required; failed to have apt strategy/ process to assess internal capital amount apt to cover risks exposed to.

Ulster Bank Ireland Limited incorp in Ireland w business in Dublin, Ireland

Settlement Agreement between the Central Bank of Ireland and Ulster Bank Ireland Limited, 14 November 2012 http://www.centralbank.ie/publications

SAN, CON, DIS

IRE Central Bank of Ireland

1.633

—



12





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2012

PPI mis-selling redress provision utilised during 2012.


RBS Group, Annual Report and Accounts 2012, 27 February 2013 pdf p47/doc p45 and pdf p49/doc p47 and pdf p432/doc p430 til pdf p433/doc p431 Note 1 re PPI

PPI UK FSA, FOS 960.000

PPI provisions 01.01.12: GBP 745M. New PPI provisions in 2012: GBP 1110M. PPI provisions 31.12.12: GBP 895M. PPI redress paid during 2012: GBP 960M (actual payment, not a provision).

RBS 31/12/2012

Interest Rate Hedge Products (IRHP) redress provision utilised in 2012.Non-sophisticated customers were mis-sold at least one of the three: structured collars; interest rate hedging products;

The Royal Bank of Scotland Plc (RBS)Group SecretariatRBSincorp in UKw business in Edinburgh, Scotland

RBS Group, Annual Report and Accounts 2012, 27 February 2013pdf p47/doc p45 and pdf p49/doc p47 and pdf p432/doc p430 til pdf p433/doc p431Note 2 re IRHP

MIS, CON

UK FSA, FOS 24.000

IRHP provisions 01.01.12: GBP 0. New IRHP provisions in 2012: GBP 700M. IRHP provisions 31.12.12: GBP 676M. IRHP redress paid during 2012: GBP 24M (actual payment, not a provision).



13





Code (See CCP2)



Amount1 [GBP M]


or caps.Sale of interest rate hedging products to some small and medium sized businesses that were classified as retail clients under FSA rules.

RBS 31/12/2012

Other Customer Redress provision utilised RBS wronged a substantial number of customers and paid redress during 2012. Individually rather small amounts are lumped together in relation to other retail


RBS Group, Annual Report and Accounts 2012, 27 February 2013 pdf p47/doc p45 and pdf p49/doc p47 and pdf p432/doc p430 til pdf p433/doc p431 Note 3 re OTHER CUSTOMER REDRESS

OTH UK FSA, FOS 96.000

ORetP provisions 01.01.12: GBP 0. Transfer accruals and other liabilities: GBP 119M. New ORetP provisions in 2012: GBP 141M. Retour provisions in 2012: GBP (2M). ORetP provisions 31.12.12: GBP 162M. ORetP redress paid during 2012: GBP 96M (actual payment, not a provision).



14





Code (See CCP2)



Amount1 [GBP M]


products (ORetP).

RBS 31/12/2012

Litigation provision utilised in 2012. RBS is party to legal proceedings in the United Kingdom, the United States and other jurisdictions. Litigation provisions end of 2012 related to numerous proceedings; no individual provision is material, however.


RBS Group, Annual Report and Accounts 2012, 27 February 2013 pdf p47/doc p45 and pdf p49/doc p47 and pdf p432/doc p430 til pdf p433/doc p431 Note 6 re LITIGATION

OTH UK, USA, EMEA, etc

FAS, US DOJ, etc

126.000

Litigation provision 01.01.12: GBP 5M. Transfer accruals and other liabilities: GBP 111M. Currency translation and other movements: GBP (4M). New Litigation provision in 2012: GBP 190M. Litigation provision retour: GBP (8M). Litigation provision 31.12.12: GBP 168M. Litigation provision used during 2012: GBP 126M (actual payment, not a provision).



15





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2012

Technology Incident (TI) Redress Provision utilised during 2012. TI affected RBS transaction batch processing; payments were subject to considerable delay. Cause investigated by independent external counsel with the assistance of third party advisors.


RBS Group, Annual Report and Accounts 2012, 27 February 2013 pdf p47/doc p45 and pdf p49/doc p47 and pdf p432/doc p430 til pdf p433/doc p431 Note 7 re TECHNOLOGY INCIDENT Details/discussion/uncertainties in Note 32

CON UK, Ireland FSA 148.000

TI provision 01.01.12: GBP 0M. Currency translation and other movements: GBP 1M. New TI provision in 2012: GBP 175M. TI provision 31.12.12: GBP 28M. Litigation provision used during 2012: GBP 148M (actual payment, not a provision).

Total (CC 2012): GBP 1,364.38 M



16





Code (See CCP2)



Amount1 [GBP M]


2013

RBS 06/02/2013

Settlement: - in relation to investigations into submissions, communications and procedures around the setting of the London Interbank Offered Rate (LIBOR). - Breaches of Principles 5 and 3 of the FSA's Principles for Business

The RoyalBank of Scotland Group plc (RBS Group)Incorporated in UKw/ business in Edinburgh, Scotland

FSA Final Notice01_RBS_2013_FSA FN_6Feb.pdf

MAB, CON

UK FSA 87.500

Between January 2006 and March 2012 (“the Relevant Period”), RBS breached Principle 3 of the FSA’s Principles for Businesses and, between October 2006 and November 2010, RBS breached Principle 5. In order to benefit its derivatives trading books, RBS sought to manipulate LIBOR in connection with its own submission of rates that formed part of the calculation of Japanese yen (“JPY”) and Swiss franc (“CHF”) LIBOR and also sought to influence other banks’ JPY LIBOR submissions. RBS also inappropriately considered the impact of LIBOR and RBS’s LIBOR submissions on the profitability of transactions in its money market trading books as a factor when making (or directing others to make) JPY, CHF and USD LIBOR



17





Code (See CCP2)



Amount1 [GBP M]


submissions. RBS’s misconduct undermined the integrity of LIBOR.

RBS 06/02/2013

Settlement: in relation to investigations into submissions, communications and procedures around the setting of the London Interbank Offered Rate (LIBOR).

The Royal Bank of Scotland Group plc (RBS Group) Incorporated in UK w/ business in Edinburgh, Scotland

Full Annual Results 2013, 27/2/2014 and 02_RBS_2013_PressR_CFTC.pdf

MAB, CON

USA CFTC 196.090

USD 325M + USD150M=USD 475M], approx. GBP 296.875M

RBS February

2013

RBS Securities Inc. submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured, fined $27,500 and required to revise its WSPs regarding TRACE new issue reporting.

RBS Securities, Inc Stamford Connecticut-based RBS, then known as Greenwich Capital Markets.

04_RBS_2013_FINRA.pdf

CON USA FINRA 0.017

Case Reference: #2010025470801



18





Code (See CCP2)



Amount1 [GBP M]


RBS 30/04/2013

Civil money penalty: for violations of section 5 of the Federal Trade Commission (FTC) Act.

RBS Citizens, N.A

05_RBS_2013_OCC_Order.pdf

MIS, CLI USA OCC 3.017

RBS 30/04/2013

The Office of the Comptroller of the Currency (OCC) ordered the bank to pay approximately $2.5 million in restitution to 265,000 affected customers.

RBS Citizens, N.A

05_RBS_2013_OCC_Order.pdf

MIS USA OCC 1.508



19





Code (See CCP2)



Amount1 [GBP M]


RBS 01/05/2013

Settlement: over allegations of inaccurate or misleading disclosures involving the banks' overdraft protection programs, checking rewards program, and recurring electronic fund transfers. Civil fines: USD 10M

RBS Citizens, N.A. and Citizens Bank of Pennsylvania, a state bank affiliate of RBS Citizens, N.A.

Full Annual Results 2013, 27/2/2014 (RBS_2013_Full Annual Results_27022014)

MIS USA OCC; FDIC 6.034

The alleged violations took place between September 2007 and September 2011 and were purportedly discovered during regulatory examinations, which highlight the importance of conducting regular internal examinations to identify and address any potential issues. In April 2013, the bank subsidiaries consented to the issuance of orders by their respective primary federal banking regulators, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) (the Consent Orders).The Consent Orders require the bank subsidiaries (RBS Citizens, N.A and Citizens Bank of Pennsylvania) to pay a total of USD 10M in civil penalties, to develop plans to provide restitution to affected



20





Code (See CCP2)



Amount1 [GBP M]


customers. The amount was anticipated to be approximately USD 8M. A civil monetary penalty to develop plans to provide restitution to affected customers, to cease and desist any operations in violation of section 5 of the Federal Trade Commission Act, and to submit to the regulators periodic written progress reports regarding compliance w/ the Consent Orders.



21





Code (See CCP2)



Amount1 [GBP M]


RBS 01/05/2013

Settlement: Over allegations of inaccurate or misleading disclosures involving the banks' overdraft protection programs, checking rewards program, and recurring electronic fund transfers. Restitution to customers: USD 3.9M

The RoyalBank of Scotland Group plc (RBS Group)Incorporated in UKw/ business in Stamford, Connecticut

Full Annual Results 2013, 27/2/2014(RBS_2013_Full Annual Results_27022014)

MIS USA OCC; FDIC 2.353

The alleged violations took place between September 2007 and September 2011 and were purportedly discovered during regulatory examinations, which highlight the importance of conducting regular internal examinations to identify and address any potential issues.

RBS 16/07/2013

Penalty: Breach of rules in SUP 17 and Principle 3.


FCA Final Notice 07_RBS_2013_FCA FN_16July.pdf

DIS UK FCA 5.620

This event was not mentioned on Annual Results. Between 5 November 2007 and 1 February 2013 (the “Relevant Period”), RBS failed to report accurately approximately 44.8 million transactions; and between 5 November 2007 and February



22





Code (See CCP2)



Amount1 [GBP M]


2012 failed entirely to report approximately 804,000 transactions, that it executed.

RBS 07/11/2013

Settlement: - Relating to due diligence conducted in connection with a 2007 offering of residential mortgage-backed securities and corresponding disclosures. - Violation of Sections 17(a)(2) and (3) of the Securities Act 1933.


08_RBS_2013_SEC_Misleading Investors in Subprime RMBS Offering.pdf 08a_RBS_2013_SEC_RBS Group.pdf 08b_RBS_2013_SEC_RBS Securities_03122013.pdf

OTH USA SEC 29.089



23





Code (See CCP2)



Amount1 [GBP M]


RBS 07/11/2013

Settlement: - Relating to due diligence conducted in connection with a 2007 offering of residential mortgage-backed securities and corresponding disclosures. - Violation of Sections 17(a)(2) and (3) of the Securities Act 1933.


08_RBS_2013_SEC_Misleading Investors in Subprime RMBS Offering.pdf 08a_RBS_2013_SEC_RBS Group.pdf 08b_RBS_2013_SEC_RBS Securities_03122013.pdf

OTH USA SEC 63.677

Pursuant to the settlement, RBS Securities Inc without admitting or denying the SEC's allegations, consented to the entry of a final judgement ordering certain relief, including an injunction and the payment of approximately USD 153M. These payments are for: -disgorgement ($80,352,639) - Prejudgment interest ($25,190,552), and - Civil Penalty ($48,211,583).

RBS 31/12/2013

Provision utilised as at 31 December 2013: - PPI redress


Full Annual Results 2013, 27/2/2014 Note 3 re PPI

PPI UK FCA, FOS 869.000

The remaining provision provides coverage for approximately twelve months for redress and administrative expenses, based on the current average monthly utilisation.



24





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Provision utilised as at 31 December 2013: - Interest Rate Hedge Products (IRHP) redress.


Full Annual Results 2013, 27/2/2014 Note 3 re IRHP

MIS, CON

UK FCA, FOS 149.000

The RBS Group has made provisions totalling GBP 1.25 bn to date for this matter, including GBP550M in 2013, of which GBP0.2bn has been utilised at 31 December 2013.

RBS 31/12/2013

Provision utilised as at 31 December 2013:- Other Customer Redress


Annual Report, Note 22 (RBS_2013_AR&A.pdf)

OTH UK 206.461

RBS 31/12/2013

Provision utilised as at 31 December 2013: - LIBOR Investigations



MAB, CON

UK, USA 4.410



25





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Provision utilised as at 31 December 2013: - Other Regulatory provisions utilised



OTH Global 17.224

RBS 31/12/2013

Provision utilised as at 31 December 2013: - Litigation provision utilised



OTH Global FCA, CFTC, USDOJ

147.000

RBS is party to legal proceedings in the United Kingdom, the United States and other jurisdictions.



26





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Provision utilised as at 31 December 2013: -Technology Incident (TI)


Full Annual Results 2013, 27/2/2014

CON, OPE

UK, Ireland FCA 28.000

This is a joint investigation conducted by the FCA together with the UK Prudential Regulation Authority (PRA). Separately the Central Bank of Ireland has initiated the investigation. In June 2012, the Group experienced a technology incident that affected its transaction batch processing. Provisions of £175 million were charged during 2012 to meet the waiver of fees and interest; redress for customers of the Group; and other costs principally staff costs. These costs have now been settled.

Total (CC 2013): GBP 1,816.00 M

Total (CC 2009-2013): GBP 3,543.71 M



27





Code (See CCP2)



Amount1 [GBP M]


Provisions as at 31 December 2013

RBS 31/12/2013

Financial Provision: - against the Settlement in relation to investigations into submissions, communications and procedures around the setting of the London Interbank Offered Rate (LIBOR).

RBS Securities Japan

Full Annual Results 2013, 27/2/2014 and 03_RBS_2013_PressR_USDOJ.pdf 03a_RBS_2013_Plea agreement.pdf 03b_RBS_2013_DPA.pdf

MAB, CON, PVN

USA USDOJ

30.168

As part of the agreement with the DOJ, RBS plc entered into a Deferred Prosecution Agreement in relation to one count of wire fraud relating to Swiss Franc LIBOR and one count for an antitrust violation relating to Yen LIBOR.

RBS 31/12/2013

Financial Provision - against the Settlement in relation to investigations into submissions, communications and procedures around the setting of the London Interbank Offered Rate


Full Annual Results 2013, 27/2/2014 and 03_RBS_2013_PressR_USDOJ.pdf

MAB, CON, PVN

USA USDOJ

60.335

As part of the agreement with the DOJ, RBS plc entered into a Deferred Prosecution Agreement in relation to one count of wire fraud relating to Swiss Franc LIBOR and one count for an antitrust violation relating to Yen LIBOR.



28





Code (See CCP2)



Amount1 [GBP M]


(LIBOR).

RBS 31/12/2013

Financial Provision:- against the settlement of a penalty to resolve investigations by the European Commission into Yen LIBOR competition infringements.


Full Annual Results 2013, 27/2/2014 and European Commission Press Release09_RBS_PressR_EU_IP-13-1208_EN.pdf

MAB, CON, PVN

EEA European Commission

216.155

This payment is covered by provisions already made by RBS.The RBS Group agreed to pay settlement penalties of approximately EUR 260M (EUR 260,056,000). As a reference, the Press Release of the Settlement was dated of 4/12/2013. The payment was on February 2014.

RBS 31/12/2013

Financial Provision: - against the settlement of a penalty to resolve investigations by the European Commission into EURIBOR competition infringements.


Full Annual Results 2013, 27/2/2014 and European Commission Press Release 09_RBS_PressR_EU_IP-13-1208_EN.pdf

MAB, CON, PVN

EEA European Commission

108.889

This payment is covered by provisions already made by RBS. The RBS Group agreed to pay settlement penalties of approximately EUR 131M (EUR 131,004,000). As a reference, the Press Release of the Settlement was dated of 4/12/2013. The payment was on February 2014.



29





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Financial Provision: against the fine for violations US sanctions against Iran, Sudan, Burma and Cuba.


Full Annual Results 2013, 27/2/2014 (RBS_2013_Full Annual Results_27022014) 10a_RBS_2013_Fed NY.pdf 10_RBS_PressR_Reuters_US Sanctions.pdf

SAN, PVN

USA

Federal Reserve System (Fed), the New York State Department of Financial Services (DFS), and the Office of Foreign Assets Control (OFAC)

60.335

The Group and The Royal Bank of Scotland plc announced that they had reached a settlement with the Board of Governors of the Federal Reserve System (Fed), the New York State Department of Financial Services (DFS), and the Office of Foreign Assets Control (OFAC) with respect to The Royal Bank of Scotland plc's historical compliance with US economic sanction regulations outside the US. In settlement with the above authorities, The Royal Bank of Scotland plc agreed to pay US$100 million in total, including US$50 million to the Fed, of which US$33 million was deemed to satisfy the OFAC penalty, and US$50 million to DFS. As a reference, the settlement was dated of 11/12/2013.



30





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Financial Provision: New Jersey Carpenters Vacation Fund et al. V. The RBS plc et al., has been settled in principle for $275 M subject to documentation and court approval.


Full Annual Results 2013, 27/2/2014 Note 13

OTH, PVN

USA -- 165.923

RBS 31/12/2013

Financial Provision: - PPI provision and related costs as at 31 December 2013


Full Annual Results 2013, 27/2/2014 Note 3 re PPI

PPI, PVN UK FCA, FOS 926.000

Total PPI provisions by RBS since beginning 2013: GBP 895M. Total provisions booked for PPI redress and expenses at 2013: GBP 900M Total PPI redress paid by RBS since beginning 2013: GBP 869M. Provisions for PPI and related costs down £210 million form 2012. Out of the cumulative provision of £3.1 billion, £2.2 billion had been utilised at 31 December 2013. The remaining £0.9 billion covers



31





Code (See CCP2)



Amount1 [GBP M]


approximately twelve months at current levels of redress and administrative expenses. Of the £3.1 billion cumulative charge, £2.8 billion relates to redress and £0.3 billion to administrative expenses.

RBS 31/12/2013

Financial Provision: - Interest Rate Hedge Products (IRHP) provision as at 31 December 2013.


Full Annual Results 2013, 27/2/2014 Note 3 re IRHP

MIS, CON, PVN

UK FCA, FOS 1,077.000

Total IRHP provisions by RBS since beginning 2013: GBP 676M. Total provisions booked for IRHP redress and administration costs at 2013: GBP 550M. Total IRHP redress paid by RBS since beginning 2013: GBP 149M. Provisions of GBP 550 million were booked for Interest Rate Hedging Product redress and administration costs, down GBP 150 million from 2012. The cumulative charge was GBP 1.25 million at 31 December 2013. RBS expects to complete IRHP sales review and provide basic redress to entitled customers by end-May 2014



32





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Financial Provision:- Other Customer Redress provision


RBS_2013_AR&A.pdfNote 22

OTH, PVN

UK 337.000

RBS wronged a substantial number of customers and paid redress during 2013.The Group has provided for customer redress in relation to certain other retail products. None of these provisions are individually material.

RBS 31/12/2013

Financial Provision: - LIBOR Investigations provision as at 31 December 2013


Annual Report 2013

MAB, CON, PVN

UK 0.453

The Researcher has subtracted the entries (LIBOR and EURIBOR) from the data within the AR and recorded as a net figure. Net amount of litigation provisions as at 31 December 2013: GBP 0.455M In the absence of a breakdown of the GBP 416 million, this methodology is the most appropriate in order to capture the total financial output in respect of litigation, regulatory and similar matters.



33





Code (See CCP2)



Amount1 [GBP M]


RBS 31/12/2013

Financial Provision: - Other Regulatory Provisions (ORP) as at 31 December 2013


RBS_2013_AR&A.pdf Note 22

OTH, PVN

Global 89.665

RBS 31/12/2013

Financial Provision: - Litigation provisions as at 31 December 2013


Full Annual Results 2013, 27/2/2014

MAB, CON, PVN

UK, USA - 1,852.077

Regulatory and legal actions: in respect of matters related to mortgage-backed securities and securities related litigation following recent third party litigation settlements and regulatory decisions. Total Regulatory and Legal provisions by RBS since beginning 2013: GBP 381 M. Total provisions booked for Regulatory and Legal redress at 2013: GBP 2,394M Total Regulatory and Legal redress paid by RBS since beginning 2013: GBP 270M.



34





Code (See CCP2)



Amount1 [GBP M]


Provisions of GBP 2,394M were booked for regulatory and legal actions: includes costs recognised within operating expenses, and Litigation provision driven both by large number of cases outstanding and precedent of recent settlements by other banks, largely in RMBS. The Researcher has subtracted the entries from the data within the AR and recorded as a net figure: Net amount of litigation provisions as at 31 December 2013 =GBP 1,852.077 million In the absence of a breakdown of the GBP 2,018 million, this methodology is the most appropriate in order to capture the total financial output in respect of litigation, regulatory and similar matters.

Total (Provisions as at 31 December 2013): GBP 4,924.00 M

Grand Total (CC 2009-2013 + Provisions as at 31 December 2013): GBP 8,467.71 M

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