Professor Philip Lane:

Let me make several points about that. One is that in many of these institutions there has been significant internal turnover. The management teams are different and the banks themselves, under the pressure of their leadership, have had to take a big look at how they operate. A basic issue is poor documentation and being unclear to their customers and themselves about what exactly a product means. It is not just us. The European momentum is to have much clearer contracts and a greater amount of information provided. It is to recognise that the circumstances of the world can change and that we should be crystal clear about what people understand going into a contract. That basic systems-and-clarity issue is important. It is also the case that a great deal of our consumer protection work these days is about bringing to the attention of boards the fact that part of the work of a board relates to governance and that ensuring staff on the front line who are designing these products and interacting with customers take seriously their obligation to put the customer first. That is an ongoing engagement. Ultimately, the culture issue is being pushed partly by us. It is definitely in the long-term interests of the banks to elevate the protection-of-consumers agenda within organisations. In this process, many hundreds of millions are going to be spent, not just in payouts but in the internal costs of running it. Not just here, but around the world, there have been so many conduct scandals in recent years that it creates a major incentive for the banks to change their ways. We have seen in this process, however, that they have relied on lawyers to narrow down the scope of the examination, which indicates that this is far from a revolution in how the banks operate.