Recommendation 9

The Bank began collecting Scheme loan data from the 24 Scheme lenders in July 2021, where lenders provide data to the Bank via a collections system. The Bank said that it holds loan data from lenders across 70 different datapoints, including the name and address of the borrower, term of the loan and size. It explained that it was aggregating this data from all of the Scheme lenders and interrogating it to spot trends and errors.17 Despite the Department and the Bank telling us that they had a “rich” and “comprehensive” loan dataset, the NAO found that lender data can be unreliable as the system depends on lenders submitting accurate and timely data, and each lender reports it on a different basis.18 Some lenders might choose not to report suspected fraud, which makes comparisons subjective; while some lenders do not share their underlying data.19 The Bank wrote to us and told us that it was working with lenders to understand what was driving these differences, such as different business models, or that some lenders might not have had a pre-existing relationship with Scheme borrowers.20 Reliance on lenders for recoveries