Professor Philip Lane:

I will ask Ms Rowland to comment on the enforcement dimension of the question in terms of looking at files. Even someone who does not know anything about the individual banks or the details, that is, the man on the street, can point to a number of basic issues. One is culture and, fundamentally, this comes back to a lot of our concerns. We think there is a common culture across the banks, which is that if there is any ambiguity or area of doubt about how to interpret a contract, to interpret it in the bank's favour rather than the customer's favour. That was a common dynamic across the system. Second, as the Deputy said, given the movements in funding costs and in interest rates, the economic incentive for these banks was essentially to interpret any possibility of making their own profitability higher to the detriment of customers. There are common factors there. In a similar situation, there is a common culture, which comes back to many things about the banks. In addition, there were the internal decision-making and other processes of individual banks. Ms Rowland will comment on the information we are gathering.