Recommendation 16

The Scheme has also made trade-offs in its response to countering fraud and the associated deterrent effects. The Department based its counter-fraud response on the 31 Qq 15, 16 32 Qq 74–75 33 Qq 74–75, 83 34 Correspondence from Catherine Lewis La Torre, Chief Executive, British Business Bank, Re Bounce Back Loans, 27 January 2022, published 31 January 2022 35 Equifax Written Evidence, BLS0001. 36 Q71 37 Qq 56–58, 61 38 Qq 61, 66, 79–80; C&AG’s Report, Figure 10 39 Qq 59, 60 40 Correspondence from Catherine Lewis La Torre, Chief Executive, British Business Bank, Re Bounce Back Loans, 27 January 2022, published 31 January 2022 14 Bounce Back Loans Scheme: Follow-up return on investment from recovering fraudulent loans within three groups: top-tier, mid- tier and bottom-tier fraud cases. The Department defined top-tier fraud cases as those involving organised crime groups with sums of more than £100,000; mid-tier fraud cases as having some evidence that individuals acted dishonestly but not on a large scale; and bottom-tier cases as those where individuals might have received loans dishonestly, for example, by misstating their turnover on the application. It is focusing its efforts on the top-tier cases of organised crime; and decided not to focus its investigative resource on borrowers who have overstated turnover by less than 25%, if there were no other fraud risk indicators.41