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New sheriff in town: record fine for RBS over bad data

24 July 2013. The FCA’s Enforcement and Financial Crime Division published its final notice of a £5,620,000 fine imposed on RBS for serious transaction reporting failures- the fine was subject to a 30% reduction for early settlement. The FCA found that between November 2007 and February 2013, RBS misreported 44.8 million transactions and entirely failed to report 804,000 (37% of all deals over the period), thereby breaching its obligations under 17.1.4R and Principle 3. The FCA acknowledged that the errors were neither deliberate nor profit-making and that the ABN Amro takeover had worsened an already failing transaction reporting process- the combined bank had 38 different transaction reporting systems.  Between 2010 and 2012 RBS spent £14.45 million on transaction reporting, substantially reducing the complexity and fragmentation of their reporting process. The cost in lost reputation and adverse publicity is harder to quantify.

This fine is the largest to date and marks the debut for the new penalty regime. The new centrality of data management should by now be apparent to all market participants. The new regulator seems intent on hammering the point home.

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