The Dame Linda Dobbs Review
Dame Linda Dobbs DBE has been appointed by Lloyds Banking Group ("LBG") to consider whether the issues relating to HBOS Reading were investigated and appropriately reported to authorities at the time by LBG, following its acquisition of HBOS.
The independent legal assessment will cover the period following HBOS’s acquisition by LBG, in January 2009, through to the conclusion of criminal proceedings commenced against six individuals in connection with the HBOS Reading fraud. In addition, the Review will examine relevant evidence from before 2009 in order to assess what LBG knew or should reasonably have known about what happened at HBOS Reading by the time of the acquisition.
Dame Linda's appointment was announced by LBG on 26 April 2017. LBG's announcement is available here.
We have received a number of enquiries recently from interested parties about the timing of the Dobbs Review. Consequently, I would like to give you an update on where we have got to in the process.
When I was appointed to carry out this Review, the expectation was that it would be a relatively short exercise which could be finished in a matter of months - and certainly well under a year.
As we set out on our work and the scale and scope of the undertaking became clearer, it was apparent that it would take much longer to conduct the inquiry.
The Dobbs Review covers a period of eight years from Lloyds Banking Group (LBG) acquiring HBOS in January 2009 until the conclusion of the criminal trial in January 2017. However, because our terms of reference require us to assess not only what LBG knew about the HBOS Reading affair, but also what it “should have known about through reasonable diligence”, we need to examine issues extending back well before 2009 and in some cases as far back as 2002.
Unlike the police investigation, Operation Hornet, which focused on a small number of specific examples of fraud at HBOS Reading and took about six years to bring to trial, the Dobbs Review is examining the treatment of approximately 80 businesses that came under HBOS Reading as well as the involvement of LBG during the Police investigation and other important issues.
I intend to give a detailed account of the work involved in carrying out the Review when I submit my report so that readers can have a full understanding of what has been involved. What I can say at this stage is that we have processed and analysed in excess of 150,000 documents, some running to hundreds of pages each. The Review is still receiving additional material. We have interviewed approximately 100 witnesses, including those affected by the HBOS Reading fraud as well as some of the police officers involved in Operation Hornet. The final stage of our work will be the interviews with LBG executives and employees. We hope to complete all the interviews this autumn.
There are more than 50 barristers working on the Review. However, due to the complexity of the inquiry, it has been necessary to interview witnesses in a logical sequence, to avoid having to go back to witnesses for further evidence.
This has inevitably affected the timing. Each interview takes considerable preparation. For obvious reasons, we needed to interview complainant witnesses and the police before interviewing LBG executives and employees.
The timing of some of these interviews is outside our control. However, we still aim to submit our report to LBG during the winter of 2020.
I am conscious that people want answers to the questions we have been asked to address. Our intention has always been to finish our work as soon as possible, consistent with doing a thorough job. Anything less would be a disservice to those affected by the HBOS Reading fraud to whom I am extremely grateful for their understanding, patience and assistance.
Dame Linda Dobbs
Dame Linda will assess whether, between 19 January 2009 and 30 January 2017, information about issues relating to HBOS Reading which LBG knew, or should have known about through reasonable diligence, was properly investigated and appropriately reported to the relevant authorities. As part of this assessment, the Review will examine relevant evidence from before 2009 in order to assess what LBG knew or should reasonably have known about what happened at HBOS Reading by the time of the acquisition.
Further detail as to the Scope of the Review is available here.
To view a copy of the guide, click here.
The Review welcomes comment and submissions from interested parties. Evidence or information relevant to the inquiry should be submitted directly via email to firstname.lastname@example.org.
A copy of Dame Linda's announcement inviting submissions is available here.
LBG’s clear position is that anyone with relevant information can provide it to the Review. The confirmation letter is available here.
Dame Linda was the first non-white High Court judge to be appointed in the UK and before that she was a leading barrister and QC, specializing in fraud and white collar crime cases. Her professional biography is available here.
All media enquiries concerning the Review should be addressed to:
Peter Wilson-Smith +44 (0)20 7043 4604 or +44 (0)7979 526152
Jimmy Chen +44 (0)20 7043 4606 or +44 (0)7787 492922