Update on IRHP final report

September 2021 update

This information has been updated to reflect that John Swift QC’s final report on the FSA/FCA’s intervention on Interest Rate Hedging Products is now expected to be published by the end of 2021

John Swift QC, the Independent Reviewer appointed to lead the review of the supervisory intervention on Interest Rate Hedging Products, provided the FCA with his draft report earlier this year and has been carrying out a substantial representations process. The final report is now expected to be published by the end of 2021 following the conclusion of the representations process, which is nearing completion.

The purpose of the representations process is to ensure public reports are fair. It provides an opportunity for any people or organisations that are identifiable and may be criticised, to respond and comment before the report is finalised.

The Review covers the period from 1 March 2012 to 31 December 2018. This enables the Independent Reviewer to look at both the implementation and operation of the pilot and subsequently the full Redress Scheme which involved a number of regulated entities and skilled persons.

The Review has taken longer than originally anticipated as a result of the complexity of the many issues under review, the number of stakeholders and witnesses involved, and the large volume of material to be considered and analysed (over 1 million documents). Additionally, the Review was affected by the impact of coronavirus (Covid-19) pandemic.


The Review was commissioned on 20 June 2019 by the Non-Executive Directors of the Financial Conduct Authority (FCA).

John Swift QC was appointed on 20 June 2019 to carry out the Lessons Learned Review into the supervisory intervention on IRHPs.  Under the Terms of Reference, the Review was to be completed within a period of 15 months beginning on the date Mr Swift was appointed by the FCA.

The target date was previously revised on 20 March 2020 to early 2021 and on 11 March 2021 to summer 2021.

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