CLLS has responded to Treasury's consultation on sanctions for directors of failed banks. It notes there is no proposed definition of "failed bank" and says there must be one, as determining what a failed bank is and the point at which failure happens will be critical. It also says the policy must be clearer on what it means by "directors" and the extent to which the regime would apply to shadow directors and senior managers. The remainder of the response sets out concerns over the practical and proportionate application of the regime. (Source: CLLS Responds on Bank Director Sanctions)