SUBMISSION FROM LLOYDS BANKING GROUP

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SUBMISSION FROM LLOYDS BANKING GROUP Introduction 1. Lloyds Banking Group ( LBG ) is one of Scotland s largest private sector employers and a major contributor to the Scottish economy. Our registered office is in Edinburgh and our Scottish headquarters are at The Mound. Our main brands in Scotland include Bank of Scotland ( BOS), Black Horse Finance (BH), Scottish Widows ( SW ) and Scottish Widows Investment Partnership ( SWIP ). 2. We welcome the opportunity to contribute to the Economy, Energy & Tourism Committee's inquiry into the way forward for the financial services sector in Scotland. We have read the eleven key questions to which you are seeking answers and focussed our answers on the future rather than the past as we understand that the Committee's wish is for the inquiry to be forwardlooking. We can understand that there may be some requirement for scenesetting and to assist we have provided a summary of what led to the financial crisis. 3. LBG has been in receipt of UK government assistance. The taxpayer currently owns just over 43% of the Group. Along with all UK banks in receipt of state aid, we are working closely with HM Treasury to demonstrate to the European Commission that the Group has a strong plan to exit state aid. At this stage it is too early to say what the result of this review will be. 4. We firmly believe that despite what has happened, Scotland remains a strong player in global finance. Firms in the insurance and asset management area have largely come through the recent crisis in good shape and most reports into the competitiveness of the financial sector have confirmed Scotland has maintained a strong position. The Financial Crisis 5. In looking at the current crisis and what needs to be done, we believe it would be helpful for the committee to split the crisis into two parts the financial markets crisis and the deteriorating global economy. 6. Coming into 2008, the UK economy enjoyed 60 consecutive quarters of sustained expansion. Inflation remained very low globally and in the UK household incomes grew strongly and asset markets boomed, notably housing. This booming economy meant that demand for borrowing outpaced the growth of savings. Banks, therefore, increased their borrowing from the financial markets to meet this demand. At the same time, there was a search for yield by investors who wanted to invest in instruments that would give them higher returns. This, with the demand for borrowing, led to a huge growth in financial innovation and more complex structured credit products. 7. The current banking crisis has happened essentially because of a collapse of confidence which has caused the money and capital markets to stop working properly. In a world which has become very risk-averse, banks and

other investors have become reluctant to lend to each other. All banks, including the stronger ones, have therefore faced increased difficulty sourcing funding, this has meant their ability to lend in turn to their customers has been affected. 8. The banks which have borrowed most from the markets have been the most affected. About Lloyds Banking Group in Scotland 9. LBG is the parent company for a number of eminent Scottish companies and brands. Bank of Scotland and Scottish Widows will be our flagship brands from now on with BOS operating as LBG's high-street branch and business bank in Scotland and SW operating as our life and pensions brand throughout the UK. 10. Although we are going through a major integration programme, we remain one of Scotland's largest employers and its largest financial services employer with well over 20,000 staff including a large number of highly-skilled and senior executive roles. 11. We have Scotland's largest network of high-street bank branches and feefree ATMs including several mobile branches in rural areas of Scotland. 12. As already stated, Scotland is home to a number of LBG headquarters sites including the UK-wide Insurance division. In addition, around one-fifth of the top 500 LBG executives work in Scotland, reflecting the extraordinary pool of talent that exists in the country s financial sector and the emphasis LBG places on having a significant presence in Scotland. The Mound is the Group's Scottish Headquarters and will be the Registered Office for the Group as a whole. We will continue to hold our AGMs in Scotland. 13. LBG is, and will continue to be, a substantial investor in Scotland's communities, donating grants, undertaking charity work and sponsoring community events such as the Great Scottish Run Scotland's largest mass participation outdoor event. We believe that we have a social as well as an economic role in Scotland and we take it very seriously. LBG's restructure 14. Lloyds TSB ("LTSB") and Halifax Bank of Scotland ("HBOS") officially came together as LBG on 16 th January 2009. Our integration programme one of the biggest ever undertaken is proceeding well and is ahead of schedule. We have said that it will take two to three years to complete however we have generated over 100m of cost savings in the first six months which is an important step in the right direction as the Group strives to return to profit. 15. Some of the announcements we have made in the last six months have regrettably involved a reduction in the number of roles across Scotland. This is an unfortunate consequence of the new Group eliminating the inevitable

duplication which existed when LTSB and HBOS came together. We have worked with or colleagues and the trades unions throughout the process of these announcements, and we are exhausting every avenue in order to minimise compulsory redundancies. 16. We have in house programmes looking at redeployment and are also working closely with the Scottish Government s Finance Sector Jobs Task Force to ensure that every avenue is pursued to help affected staff. Competition 17. The landscape of both personal and business banking in Scotland will change over the coming years, as LBG combines the BOS and Lloyds TSB Scotland ("LTSBS") high-street branch networks and business/corporate banking. Similarly, Santander has announced that its Abbey, Alliance & Leicester and Bradford & Bingley brands will combine under the Santander name. 18. Although this will clearly reduce the number of competitors, it is important to establish a context. This time last year, BOS, Royal Bank of Scotland ("RBS") and Clydesdale Bank ("CB") were the main players in the business banking market. The brands which will be removed from the market, including LTSBS, had a very small market share. Indeed, the addition of LTSBS to the BOS operation still isn't enough to take BOS above RBS in market share of business banking. 19. On the high-street, the combination of the LTSBS branch network with the BOS branch network will lead to some branch closures however, we believe the sector will remain competitive as some banks have announced an intention to expand, new entrants are emerging while there is likely to be a greater use of internet competitors. 20. We think the increasingly competitive landscape is good for our customers and good for us. We will only grow our business by being the best bank for our customers. The availability of credit 21. There has been a contrasting story on lending across LBG in the last 18 months. HBOS had severe liquidity problems during 2008 which meant that it had major constraints on its ability to lend money. However, LTSBS had no such liquidity issues and substantially increased its lending in both areas during 2008, albeit from a far smaller base. Overall, lending to homeowners increased during 2008 whilst lending to SMEs fell by a low single-digit percentage. 22. The situation has begun to change recently. Due to the stability of the new Group, BOS is now able to lend once again to its business, commercial and corporate customers and the pipeline is up and running. In addition to 'standard' lending, BOS is an active participant in the government's Enterprise Finance Guarantee Scheme ("EFG") and is helping Scottish companies

through new lending and through its Business Support Unit ("BSU"), which helps to turn around struggling businesses. We have recently been actively contacting our customer base to ensure that we are supporting them through the downturn and helping prepare them for the end of the recession. 23. We do feel, however, that it is important to place lending levels in their proper context. There is considerable public pressure on banks which are in receipt of taxpayer funding to simultaneously lend money to those who need it and to lend responsibly in order to mitigate against future losses for individuals and for the Group. Whilst in the current climate we occasionally attract criticism for not lending to individual businesses or homeowners, we have emphasised that we make decisions according to the strict, prudent risk profiles which LBG inherited from LTSB. The best way for us to protect and repay taxpayer funding, as well as to protect Scottish jobs, is to be able to compete commercially and make commercial lending decisions in the interests of the Group, even if that means some funding requests are declined. The Future 24. Lloyds Banking Group was in receipt of taxpayer funding after the acquisition of HBOS by LTSB. This was both welcome and required, and we believe that despite the cost to the taxpayer, it served the best interests of financial stability and financial sector jobs in the UK as a whole. 25. With the other major Scottish bank RBS also in receipt of government funding, there is no doubt that the focus in the UK fell primarily on Scottish banks. However, this is not a structurally Scottish problem. The fact that the two UK banks which suffered the most were Scottish is not a reflection of their roots, but of those banks' business models at the time. A number of other banks around the world suffered in a similar way. 26. LBG must now proceed with its integration and make the right decisions to protect our customers, our staff, our shareholders and the taxpayer. This is the only way for us to help enhance the reputation of our company and of Scotland as a global financial centre. 27. We firmly believe that despite what has happened, Scotland remains a strong player in global finance. Firms in the insurance and asset management area have largely come through the recent crisis in good shape. Our recent decision to transfer the investment management of funds sourced from our Halifax and Bank of Scotland bancassurance operations, our Bank of Scotland wealth management business and our Clerical Medical intermediary franchise from Insight Investment to SWIP underlines our confidence in Edinburgh and Scotland. SWIP will become a centre of excellence for the Group s asset management activity and after the transfer will manage assets of approximately 125 billion. 28. Scotland retains a major financial sector with a highly skilled workforce. We are in a period of major transition, but there is no reason why Scotland

should not cement its place as a hub for financial services and LBG is committed to playing a major part in ensuring that that is the case. Lloyds Banking Group September 2009