Bank of Scotland plc · DRN-6189151

The complaint Mrs H complains about the interest rate she has received on her savings account held with Bank of Scotland plc. Mrs H is represented by a family member in bringing this complaint, but I’ll generally refer to all submissions as being made by her directly. What happened Mrs H opened an Access Cash ISA in February 2018 which matured into an ISA Saver account a year later. In 2022, a family member started helping Mrs H with her finances before eventually being appointed as a Power of Attorney in December 2023. They were shocked to see how low the rate had been on this account and how little interest had been earned. They had concerns about the rate and whether the interest had actually been calculated correctly. Mrs H’s representative made a complaint to Bank of Scotland on her behalf. It confirmed what had happened to the account since 2018 and said that the interest had been calculated and paid correctly. It said it had provided statements and letters advising Mrs H what the interest rate was on the account, along with explaining that she could review its full range of savings accounts to see if there were other accounts that better suited her needs. Bank of Scotland did pay Mrs H £150 to recognise that it didn’t log a complaint when Mr H first raised concerns and acknowledged that it took longer than expected to respond to this. Mr H didn’t agree with this on Mrs H’s behalf and brought her complaint to this service where one of our investigators looked into it. They found that Bank of Scotland had correctly calculated and applied the interest to the account here and that there was no evidence to suggest that the rate itself wasn’t providing fair value. They said that Bank of Scotland communicated with Mrs H to make her aware of the rate she was receiving and that they weren’t persuaded that Bank of Scotland needed to recommend products to her. Mr H didn’t agree with the investigator though. He says (in summary) that it is a ‘disgrace’ how Mrs H has been treated and questioned why no letters were sent to her in 2022 and 2023. Mr H asked for Mrs H’s complaint to be passed to an ombudsman. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. To start with, I’m satisfied that Bank of Scotland has correctly calculated and applied interest to Mrs H’s account. I’ve seen nothing from either party to suggest that any errors have been made in this respect. So I’ll focus on Mr H’s concerns as to whether the interest rate on the account is fair in the circumstances here. As our investigator has explained, Bank of Scotland is free to decide on the products it offers to customers and on the interest rates its willing to pay on these. Before 31 July 2023 there

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was no requirement or obligations on Bank of Scotland to set its rates at any particular level and nor did it need to justify the rates it was offering. Mr H has mentioned the rate being as low as 0.05% at one point between 2020 and 2021, but that in itself doesn’t mean that Bank of Scotland has acted unfairly. It was entitled to set such a rate and looks to have made Mrs H aware of any changes to the rate through specific letters explaining what the changes would be and by sending her statements, in line with its relevant obligations. I’d add that I’ve seen that statements were sent in 2022 and 2023 confirming the rate. Mr H asked why there have not been any notifications of the interest rate in the same time, but that was because there were steady rises in the rate from 2022 until 2023, which Bank of Scotland was under no obligation to notify Mrs H of. So prior to 31 July 2023, I’m satisfied that Bank of Scotland has acted fairly. But as of the 31 July 2023, the FCA’s Consumer Duty was introduced into regulation. This was a higher set of standards for consumer protection which included the requirement for firms to assess their products as providing fair value. However, the FCA was clear that it isn’t the intention of the Consumer Duty to set prices and it clarified that its rules do not have this effect. Nor do these rules have the effect that Bank of Scotland should pay Mrs H the best rate for the product, or the same rate as other firms From when the Consumer Duty was introduced I’ve seen that the rate on Mrs H’s account was between 1.45% and 1.80% until Mr H complained. I see Mr H’s point that this rate seems low, but this isn’t the lowest market rate being paid at the time. Nor is it below 1% which is the level at which the FCA said it expected to see a reduction in the number of firms offering. But we have asked Bank of Scotland some questions around how it assessed this product as providing fair value. It has given this service a very limited response to our questions which is disappointing – but equally, I can’t see that this account isn’t providing fair value or that it represents a bad outcome for Mrs H – even if I realise that Mr H will see things very differently. I’ll turn now to Mr H’s concerns that Bank of Scotland could have done more to communicate the details of her account with her and to have told her about (and recommended) other products. Savings products like the one Mrs H held are ‘non-advised’ products, meaning that Bank of Scotland doesn’t offer advice in relation to them, such as suitability recommendations. Ultimately it is for customers to decide what accounts they want to hold their savings in within a competitive marketplace. Bank of Scotland’s responsibility here was to provide Mrs H with enough information to do that and having seen the letters and statements it sent, I’m satisfied it did that here. In respect of whether Bank of Scotland could have done more to help and support her when she called it and attended a branch – it’s ultimately difficult to know what was discussed during these calls and meetings because there are simply no records of these. Mr H says on Mrs H’s behalf that he can’t understand why the branch didn’t let her know about other accounts or help her get a better rate. But without any record or detailed testimony of what was discussed here, it wouldn’t be fair for me to say that Bank of Scotland could or should have done any more. In any event it seems to me more likely than not that during these meetings Bank of Scotland would have only confirmed the situation with her account, which would have been what the interest rate was at the times she spoke to it and reminded her that other accounts were available, which is what it had told her in the letters and statements it sent anyway.

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So in the circumstances here I can’t say that Bank of Scotland should do any more. It has made a fair payment of compensation in the circumstances in relation to some of the issues with how it responded to this complaint and so I make no further award here. My final decision I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs H to accept or reject my decision before 27 April 2026. James Staples Ombudsman

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