Given the impact, in human terms, of the mortgage account failings by GMAC-RFC on some of its customers in arrears, one would expect the Financial Services Authority to have taken the strongest possible disciplinary action. It is difficult, however, to gauge just how strong that action was or what it says about the FSA's disciplinary philosophy or direction generally. The stated purpose of the FSA disciplinary action against GMAC was to promote high standards by deterring GMAC from committing further compliance breaches, helping to deter others from committing similar breaches and demonstrating the benefits of compliant behaviour.
It is not possible to say whether in financial terms the penalty was such as to achieve those ends. The costs to GMAC look substantial — a £2.8m fine (reduced from £4m because GMAC did not resist), estimated redress costs of £7.7m and indeterminate administration costs. These have to be weighed against the profits (if any), however, that GMAC earned, and continues
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