Corporate report

SME banking 2002 behavioural undertakings: report on banks� compliance audit 2023

2023 audit report into whether 8 leading UK banks are complying with undertakings they gave not to bundle loans and accounts.

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In 2002, a number of banks agreed that they would no longer (except for in specific circumstances) make a small and medium-sized enterprise (SME) customer open or maintain a business current account in order to get a business loan. This practice is commonly known as ‘bundling� and was prevented by behavioural undertakings.

In 2014, 8 banks agreed to submit annual audit reports of their systems and procedures to the Competition and Markets Authority (CMA). »Ê¹ÚÌåÓýapp CMA reviews these and reports on its findings each year in the reports on compliance above.

»Ê¹ÚÌåÓýapp following 8 banks are currently subject to the bundling prohibition:

  • AIB Group (UK) plc (known as AIB NI in this report, and previously known as First Trust)
  • Bank of Ireland UK plc
  • Barclays Bank plc and Barclays Bank UK plc (together, Barclays)
  • Clydesdale Bank plc’s SME Business and Branches in Scotland branded as Virgin Money (Clydesdale)
  • HSBC UK Bank plc (HBUK). HSBC’s non-ringfenced bank HSBC Bank plc (HBEU) remains subject to the Undertakings but was released from the 2014 Agreement during 2023
  • certain group companies of Lloyds Banking Group plc, formed from the merger of HBOS plc and Lloyds TSB Bank plc (Lloyds)
  • Northern Bank Limited (Danske)
  • NatWest Group plc (NatWest) (formerly the Royal Bank of Scotland Group plc (RBS)) which includes Ulster Bank Limited (Ulster Bank) in Northern Ireland

Updates to this page

Published 8 July 2024

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