Internal whistle-blowing case

Client: UK Head-quartered Bank

Scope: Due to internal whistle-blowing concerns raised by a Bank’s employee, Ashlynwood was engaged to assist in conducting a review of the Bank’s Mortgage product offering to identify whether a breach of the Bank’s policies and procedures took place and/or whether the Bank was in breach of regulations like Financial Services and Markets Act 2000 and in particular of the Mortgage Credit Directive.

Engagement: Ashlynwood undertook a thorough review of the Bank’s policies and procedures, with detailed review of sample mortgage cases to ascertain any (a) evidence of adherence to policies and/or any circumvention of process; (b) evidence of completeness and accuracy of documentation held on file; (c) evidence of any mis-selling of products by Bank. Additionally, Ashlynwood interviewed various internal staff members of the Bank and reviewed their qualification and training; and reviewed legal advice held on file pertaining to Financial Conduct Authority (FCA) Mortgage Conduct of Business (MCOB) rules.

Outcome: Ashlynwood’s report was submitted to the Board of the Bank, with multiple recommendations to strengthen the control environment around the Bank’s Mortgage product offering.

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