On 11 December 2013, the FCA issued a Final Notice fining Lloyds TSB Bank, Halifax and Bank of Scotland (which are part of Lloyds Banking Group) a record £28,038,800 (Stage 2: 20% discount) for what the FCA deemed to be a breach of Principle 3 (management and control) in the form of serious failings in the systems and controls governing the financial incentives given to sales staff, with a corresponding risk that sales staff would sell unsuitable or unnecessary products to customers. The penalty was increased by 10 per cent due to a number of aggravating factors, including the fact that the FSA and FCA had for many years been warning firms of the need to manage and control risks to customers arising from financial incentives given to sales staff (see paragraph 6.15 onwards of the Final Notice).