Guide to the Dobbs Review

1. What is the Dobbs Review?

The Board of Lloyds Banking Group (“LBG”) appointed Dame Linda Dobbs DBE in 2017 to investigate the bank’s handling of the HBOS Reading incident which affected various SME customers.

In February 2017, following a criminal trial, two former HBOS bankers and four external consultants were sentenced to terms of imprisonment for fraud and other offences which centred around misconduct in the Impaired Assets’ office at HBOS Reading. The Dobbs Review covers a period of eight years; from the takeover of HBOS by LBG on 19 January 2009 to the end of the trial on 30 January 2017. In addition, the Dobbs 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. This means that if you have relevant evidence which you wish to give to the Review about events at HBOS Reading or about any individual named in the criminal proceedings you should contact the Review as soon as possible and in any event by the deadline of 4 p.m. on Thursday 18 April 2019.

Dame Linda has been asked by LBG, at its own expense, to conduct an independent inquiry into whether it acted appropriately in respect of its legal and regulatory obligations. In particular she has been asked to investigate:

  • What LBG knew, or should reasonably have known, about the misconduct
  • Whether LBG reported matters appropriately to the relevant authorities
  • Whether there was a cover-up.

The detailed scope of the Review can be found here.

2. Does LBG direct or control the Dobbs Review?

Dame Linda and her team are carrying out an independent inquiry and Dame Linda will be solely responsible for the conduct, content and findings of her report. Neither LBG, nor its advisers, have access to the work of the Review or to their discussions with witnesses. The Review has its own, ring-fenced IT infrastructure and confidential database.

3. Does the Dobbs Review have any powers of compulsion?

The Review is a private one. It has no powers to compel people to give evidence. However, if anybody unreasonably declines to be interviewed Dame Linda can note this in her report.

4. Will the Dobbs Review be published?

Dame Linda will submit her report to the Board of LBG and to the Financial Conduct Authority. It will be up to LBG whether the Dobbs Review’s report is made public. Dame Linda intends to write her report in a form that can be made public.

5. How is Dame Linda going about her Review?

Dame Linda and her team are receiving relevant evidence from a variety of different sources. This includes witness evidence (primarily, HBOS Reading customers and LBG personnel), internal LBG documents and reports, communications from customers and information that came to light during the criminal trial.

6. How important is the participation of HBOS Reading victims?

Essential. The Review is evidence driven and the report will only be as good as the evidence that the Review receives.

7. How do I know if my case falls within the scope of the Review?

We invite potential witnesses to read the scope of the Review. If you are not sure whether your circumstances fall within the scope, we suggest you contact the Review at info@dobbsreview.com and arrangements will be made for you to speak with a member of the team. If you believe that your case does fall within the scope, please contact the Review briefly setting out the circumstances of your case.

8. What does being interviewed involve?

If your case does fall within the scope you will be invited to provide the Review with any relevant documentary evidence. We will then arrange a time convenient to you to give evidence to the Review. This can either be in London or we will travel to meet you elsewhere if you prefer.

The interview process will be an information gathering exercise. It is informal but it will be recorded.

9. What happens if I have already been interviewed or given evidence?

The Dobbs Review is a separate inquiry, the scope of which differs from that of any previous investigation. Therefore, we want to hear from you.

10. Is there a relationship between the Dobbs Review and the Griggs Review?

No. The Dobbs Review is not involved in deciding the compensation for HBOS Reading victims and operates completely separately from the Griggs Review. There is no communication or sharing of information with the Griggs Review.

11. Can I speak to the Dobbs Review if I have signed a non-disclosure agreement (NDA) with LBG as part of a legal settlement or compensation settlement under the Griggs Review?

LBG has confirmed that customers who signed NDAs as part of a settlement with LBG, either under the Griggs Review or outside the Griggs Review, are not prevented from giving evidence to the Dobbs Review by these NDAs. In response to a direct request from Dame Linda, LBG has stated that:

…it is the Group’s clear position that all customers with relevant information are able to provide it … for the purpose of your Review.”

See here for a statement made by Adrian White on behalf of LBG.

12. Will any evidence I give be treated confidentially/anonymously?

Dame Linda may wish to include your evidence as part of her report. If you would prefer your evidence to be treated as confidential or to be anonymised arrangements can be made. Further details can be provided when you speak with a member of the team.

13. Will anyone have the right to comment on the draft report?

There is a process known as Maxwellisation. This is confined to individuals who are the subject of criticism in the draft report. The process will allow those who are the potential subject of criticism to answer those criticisms. The time allowed for comment will be brief.

14. What is the size of the Dobbs Review team?

Dame Linda has a team of more than 20 counsel including several experts in complex fraud cases and regulatory matters, and a project manager working on the Review. Peter Carter QC is Counsel to the Review and is assisted by Adam Wiseman QC.