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I asked him to put his gun down and explain the FCA’s view on the banking industry’s use of the word ‘independent’ with regard to independent enquiries and independent enquirers and in particular Russel Griggs with his cynical Review and Dame Linda Dobbs QC with her current enquiries into Lloyds’ conduct.

I pointed out the 2 dictionary definitions:

1) “free from outside control- not subject to another’s authority”

Well,Russel Griggs has been hired by Lloyds previously for consultancy work was selected by Lloyds, contracted by Lloyds and is paid by Lloyds to lend his name to the secretive compensation process. Lloyds tell Griggs what they feel is a fair offer to the victims and he simply gets out his rubber-stamp. Griggs is 100% under the ‘authority and control’ of Lloyds.NOT INDEPENDENT


Dame Linda is an entirely different matter. She is one of the most respected figures in the UK justice system. During her time as a judge she fought tirelessly to improve ethical behaviour within the judiciary.

I’m confident that in this regard Dame Linda would never be influenced by Lloyds authority or their efforts at control.

Unfortunately she does however expose herself to criticism and claims of partiality with the second dictionary definition of independent:

 2) “ not depending upon another for livelihood or subsistence”

Dame Linda Dobbs strikes me as the kind of person who has probably handled her personal finances with great prudence in which case she’s not short of a bob or two.

If I’m correct she doesn’t need Lloyds handsome remuneration package in order to subsist  but nonetheless she is being paid by Lloyds Bank to investigate Lloyds bank.

                              Dame Linda-that doesn’t smell very nice.


So, I wrote to Andrew Bailey for the FCA interpretation of independent.


I find his response in paragraph 2 utterly extraordinary given the reality of how Lloyds bank actually behaves- hence the additional questions in italics.

From: Wayne Laramee

Subject: Email of 13 September

Date: 25 September 2017 at 13:44:21 BST

To: Noel Edmonds

Dear Mr Edmonds


Please find a response from Andrew Bailey to your email of 13 September.


Yours sincerely

Wayne Laramee

Dear Mr Edmonds


Thank you for your email of 13 September.

 As I outlined in my earlier email, but which I think is important to reiterate, the business lending activity at the heart of Lloyds’ review is outside the scope of our regulated activities. This means that we cannot specify the form of any scheme to handle complaints and cannot specify the form of any scheme that is established by firms.

 You question whether anyone appointed and remunerated by Lloyds can be considered independent and specifically refer to Professor Griggs and Dame Linda Dobbs. Like other banks, Lloyds is subject to the Senior Managers and Certification Regime (SMCR). This took effect in 2016 and was introduced to provide a new accountability framework focussed on senior management. Were there to be any attempt* by Lloyds to influence the work of Dame Linda Dobbs and Professor Griggs it would run contrary to the responsibilities senior management have under the SMCR

Andrew how would you find out about any ‘ attempts*’ do you have people inside Lloyds? and cause us to take action. And what would that action be Andrew? I can therefore assure you that we have the powers to ensure that the firm does not seek to compromise the independence of the two individuals.

  In other words you have no intention of policing the process you will simply wait to find out if anyone later complains that it was corrupt after the reports have been published/suppressed? 

 Yours sincerely

Andrew Bailey


Wayne Laramée

Manager, Executive Office and Private Secretary to the CEO

25 The North Colonnade

Canary Wharf


E14 5HS


Tel:    +44 (0)20 7066 4556

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