Years too late in the view of many, the United Kingdom's Financial Conduct Authority and Prudential Regulation Authority have decided to start investigating certain former senior managers of Halifax Bank of Scotland.

In compiling a recent report on the now-moribund Financial Services Authority's enforcement policy towards the men who brought the bank down in 2008, Andrew Green QC wrote: "My conclusion, in summary, is that the scope of the FSA’s enforcement investigations in relation to the failure of HBOS was not reasonable. The decision-making process adopted by the FSA was materially flawed; and the FSA should have conducted an investigation, or series of investigations, wider in scope than merely into the conduct of Mr Cummings and the Corporate Division." In 2012 Peter Cummings became the only former HBOS banker to be penalised by the FSA as a result of the bank's financial meltdown. He was fined £500,000 and banned from finance for life, claiming all along that he was a 'scapegoat' and that there were bigger fish to fry. Lloyds rescued the bank in September 2008.

Commenting on the regulators' joint decision to wait until this moment for an investigation, the Rt Hon Andrew Tyrie, the chairman of the influential Treasury Committee, said: “Overdue doesn’t capture it. It is eight years since the collapse of HBOS in 2008. It has taken a heap of pressure from Parliament to secure appropriate action from the regulators. This has included the Treasury Committee’s demands from 2011 that the regulators conduct a full inquiry into the collapse of HBOS - work that was only concluded in November 2015; a major investigation by the Parliamentary Commission on Banking Standards – which recommended that regulators consider whether any former members of HBOS’s senior management should be subject to investigation proceedings with a view to prohibition; and a request from Parliament’s specialist advisers.

“Mr Green concluded that the FSA should have got on with this in 2009. So the FCA and PRA should conduct these investigations immediately. The lion’s share of the investigatory work should already have been undertaken in the preparation of the regulators’ report into the failure of the bank.”