The problems with Sesame's complaints handling were identified as part of the FSA's thematic review of SCARPs during March and August 2004. The FSA found that Sesame incorrectly rejected complaints from approximately 350 customers between March 2003 and October 2004. These customers had lost nearly £5.9 million. The complaints related to sales made by Sesame's legacy networks.

William Amos, Head of Retail Enforcement at the FSA, said: "Sesame has no excuse for complaints handling failures of this kind, not least because the FSA had already issued a number of publications concerning both SCARPs and complaints handling. The failings we found highlight the need for firms to implement and maintain robust complaints handling procedures and to train staff adequately ."

After the FSA identified the problems, Sesame took prompt action to ensure all affected customers were compensated and engaged external advisers to review its SCARPs complaint handling procedures and train its staff. Without the firm's co-operation and commitment to mitigation and remedial action, the penalty would have been substantially higher.