In June 2012 the FCA announced a review of the sale of around 40,000 IHRPs to ‘non-sophisticated’ customers. The FCA’s pilot review found that over 90% of the sales did not comply with regulatory requirements.
By 31 December 2014 only 15,646 of the affected businesses had received offers of redress. Just 7,863 of those offers, representing less than 20% of the original review population and perhaps less than 10% of the value of the claims reviewed (the FCA has refused to publish figures by value), were for full redress. The overwhelming majority of the affected businesses were either excluded from the scheme, or received offers that gave them no redress at all, or substantially reduced redress due to the imposition of “alternative products”, i.e. replacement IRHPs in the form of swap-for-a-swap or cap-for-a-swap outcomes.
It is apparent from the FCA’s published figures that the scheme has failed in its core purpose, which was to provide fair and reasonable redress in each case.