IRHP FAQs - Financial Conduct Authority

Interest rate hedging product review - FAQs

In addition to the information on the review and redress determination process, and on consequential loss claims, frequently asked questions have been grouped by topics below. Information on the progress of the review is updated on a monthly basis. Please browse through these questions to find out more information about the IRHP review scheme.

If your business is in financial difficulty, consult this page for information on how this affects the review of your interest rate hedging product.

If your question is not answered here, please do not hesitate to contact us.  

Independent Reviewer

Q1: How were the independent reviewers decided?

Answer:

We oversaw the appointment of the independent reviewer at each bank. During the selection process, we considered a number of factors including their skills, competence and independence.

Q2: What is the role of the independent reviewer?

Answer:

The independent reviewer will review all aspects of the proactive redress exercise and past business review. This will include the methodology and review of each individual case.

Independent reviewers will also ensure that the bank has appropriate processes for determining whether to suspend customers’ payments on a case-by-case basis.

Q3: How can I be assured that the independent reviewer is truly independent?

Answer:

We conducted a robust approval process to ensure the reviewers have the necessary skills, expertise and independence to understand both the complex aspects of IRHPs and the specific needs of small businesses. When selecting the independent reviewer for our approval, the bank had to identify any potential conflicts of interest. This included any involvement by the independent reviewer in the design of the products and sales processes being reviewed, any winding up of business customers, and any auditing services to the bank.

Where we saw potential for a conflict of interest between individual customers and the first independent reviewer appointed by the bank (or a perception that there could be a conflict), we required the banks to appoint another independent reviewer to review those cases.

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