BBA has responded to FSA’s guidance consultation on banks’ controls on investment fraud. It was surprised by several aspects of FSA’s report, specifically that FSA found banks had no clear rationale for allocating resources to investment fraud. It commented that it is not feasible in some UK banks to dedicate a team solely to investment fraud and that many banks include it in their overall anti-financial crime programmes. It noted the report did not recognise the tensions banks face in applying legal requirements in the face of the expectations of technology, for example the faster payments initiative. It also commented that many reports of fraud are not investigated because of resource limitations in the enforcement agencies. BBA also expressed regret that FSA had not consulted with it in the course of drafting the guidance. (Source: BBA Responds on Investment Fraud Guidance)