Barclays Bank · DRN-6317739

The complaint Mr B brings a complaint against Barclays Bank Plc (“Barclays”) in relation to share transfers he requested and in respect of which he now seeks compensation. I refer below to other firms involved in the background to the events – including Fineco, Degiro, and Trading 212 – only to explain what happened and my reasoning. Mr B does not make a complaint against those third parties, I am not making any findings about them, and this decision does not apply to them. What happened In 2024 Mr B had shares in two accounts with Fineco and an account with Barclays. Given Fineco was closing down its UK operations, he decided to do in specie transfers of his shares in Fineco to his Barclays account and to a newly set up Degiro account. At the same time, he wished to transfer in specie the shares in his Barclays account to the Degiro account in order to keep the Fineco account shares separate from the shares that were already in the Barclays account. Mr B says he had no issues with transferring his shares from Fineco to Degiro – a process which he says took a matter of weeks. However, he says he experienced significant issues with Barclays which caused severe delays. In October 2024, Mr B says that he instructed Barclays to transfer his shares from Fineco into his Barclays account and his shares from his Barclays account into his Degiro account, but he says due to significant failings on the part of Barclays none of these transfers took place. Mr B complained to Barclays about the overall process and in particular the delays which he considered were unjustifiable. Barclays, in its final response letter dated 7 February 2025, accepted a number of failings. These included: • Barclays could only transfer shares from or to accounts with identical account holders. In this case, Mr B’s Fineco account was a joint account, and he was proposing to send them to his Barclays account which was solely in his name and given the lack of symmetry between account holders such a transfer would not be possible. However, it accepted that it had incorrectly told Mr B that the transfer of shares from Fineco to Barclays could go ahead if the Transfer Authority Form was signed by both account holders of the Fineco account. Moreover, it also accepted that it had failed to identify this issue sooner than it should have. • It also accepted that it was at fault for significant delays in transferring the shares out from his Barclays account to his Degiro account. Barclays had deliberately held up the transfer to allow the Fineco shares to be transferred to the Barclays account first, as it had assumed that if the shares already in the Barclays account were transferred to Degiro before receipt of the shares from Fineco, this would result in the Barclays account closing as it would essentially have insufficient assets. However, it accepted it had erred in this thinking and unnecessarily held up the

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transfer to Degiro, as it had failed to consider that Mr B also had cash in his Barclays account and that as he had only requested a transfer of the shareholdings in that account, there would remain sufficient assets (in the form of cash holdings) to keep the account open. • Further, it accepted that it had erroneously asked Degiro to expect the shares that in actual fact Barclays itself was going to receive from Fineco. In so doing, it erroneously provided Degiro with a list of the shares that were to be transferred from Fineco to Barclays. It accepted this was “unacceptable” and informed its Data Protection team about the mishap. Given these failings, Barclays offered Mr B £250 compensation for the distress and inconvenience he had suffered and his overall poor experience with the transfers. Mr B initially said he attempted the transfer once more after Barclays’ 7 February 2025 final response letter, but again it did not go through. He has since clarified he did not attempt another transfer following Barclays’ letter. He claims that due to his frustration at the overall delays and concerned about a 31 March 2025 service termination deadline, he transferred the shares in his Fineco account to Trading 212 and sold the shares in his Barclays account and transferred the cash proceeds to his Degiro account and from there repurchased the same shares. In this process, he says he incurred fees related to the sale and repurchase. Mr B was not happy with the level of compensation and so brought his complaint to this Service. In particular, Mr B felt he was entitled to compensation for financial loss: (i) he had made a loss on the shares due to the delays and Barclays telling him to hold onto the shares during the transfer process (due to alleged adverse currency and market fluctuations), and (ii) he had also had to pay fees related to the sale and repurchase. He also felt the compensation did not adequately take account of the trouble he had to go through with Barclays, which he says included a data privacy breach. Our Investigator upheld Mr B’s complaint, but only partially. She concluded that Mr B was entitled to compensation for the distress and inconvenience he suffered and increased the compensation to £350. However, the Investigator did not hold that Mr B was entitled to compensation for financial loss, she says that Barclays would have eventually made the share transfers and that these losses were caused by Mr B’s own choices and failure to mitigate his losses. Mr B did not accept the Investigator’s view. His arguments included the following: • He did not sell and repurchase the shares freely but did so under duress and this in itself was an act of loss mitigation. • It would be unreasonable to expect Mr B to have faith that Barclays would eventually complete the transfer as it had given no clear explanation as to why the transfers did not take place. • It was generally unreasonable to expect Mr B to wait any longer for Barclays to effect the transfer, particularly given that in his view the transfer should have taken no longer than two weeks or so and this was a clear breach of contract by Barclays. • The Investigator did not adequately take into account the trouble Mr B was put

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through, and he provided further evidence in the form of a call log showing the numerous calls he had to make in his attempts to effect the transfers. • Had Mr B known the share transfer would have been delayed as long as it was, he would have sold the shares at the outset as he would have made a good profit on them. • He also claimed he was charged management fees (£7.49) from Barclays in respect of the abortive transfers, which he felt were unjustifiable. As Mr B rejected the Investigator’s view, the complaint came to me for decision. I issued my provisional decision on 9 April 2026. I’ve included an extract from it below. Since I issued the provisional decision, Mr B has provided factual clarifications which are reflected in the factual background above but because of their timing are not reflected in the below extract of my provisional decision. The impact of these factual clarifications on the outcome of the complaint is addressed in later sections of this decision. “I fully accept, as Barclays itself has, that the delays in the transfers were the fault of Barclays and that it likely fell short of its service obligations. For example, it likely breached (i) principle 2 of the FCA’s Principles of Business which required it to act with due skill, care and diligence, and (ii) rule 2.1.2R of the FCA Code of Business Sourcebook requiring that information be clear, fair and not misleading. The delays and Barclays’ overall conduct may well also constitute a breach of contract as Mr B claims (although, I note Mr B does not elaborate on or specify the precise terms alleged to have been breached). The central issue, however, for Mr B is that the financial loss for which he claims doesn’t flow directly and naturally from the breach but is rather the result of his own actions and his failure to mitigate his losses. In that respect, I agree entirely with the Investigator’s view. Mr B caused the claimed losses or at least failed to mitigate losses by choosing to sell the shares and repurchase them instead of waiting for the transfer to complete. Mr B has stated that the sale and repurchase was because he was under duress and that this was in itself an act of mitigating losses. However, I am not persuaded by these arguments. Mr B has alluded to the looming service termination deadline of 31 March 2025 set by Fineco as being a central reason for his decision to sell the shares as he was under the impression the shares would be automatically sold after this deadline. However, Mr B has not provided evidence that would suggest he would not have been able to transfer the shares after that deadline had elapsed. He simply states his belief at the time. Unfortunately, the evidence suggests Mr B’s belief was in fact mistaken. A wind down disclosure letter Fineco issued to customers on 31 January 2024, and which is available on their website, suggests that with respect to “Listed products and funds” (which would apply to Mr B’s shareholdings) even after the “service termination” a “[t]ransfer to another provider of your choice remains possible”. This would be in line with its regulatory obligations under UK and EU laws to carry out pre-existing contracts (i.e. in respect of the shareholdings) and protecting customer assets even when a firm ceases banking operations in a jurisdiction like the UK. Thus, the evidence suggests Mr B’s shares would not have been sold by Fineco after the 31 March 2025 deadline and that he likely would have been able to transfer the shares even after that deadline. Accordingly, the basis upon which Mr B claims he sold the shares under duress and that he was mitigating his losses is on balance not borne out. His decision to sell was unfortunately made under a mistaken assumption, rather than any imminent risk of a forced sale.

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I am also not persuaded by Mr B’s contentions that it was reasonable for him to have no faith that Barclays would have been able to carry out the transfer at all and that this justified the sale and repurchase. Mr B here centrally relies on the claim that Barclays had not provided a clear explanation as to why the transfers had not already been successful and so in the absence of that he had no belief Barclays would be able to effect the transfers at all. That is unfortunately not accurate. Barclays’ final response letter of 7 February 2025 explained quite clearly what the issues were. In particular, they were (i) the lack of symmetry of account holders between the Fineco and Barclays accounts, (ii) a misunderstanding regarding the consequences of a transfer from the Barclays account to the Degiro account, and (iii) a possible misunderstanding of which shares were to be transferred to the Degiro account. Thus, Mr B was given a clear understanding of what the issues were (which Barclays had now understood) and how these could be avoided going forward in order to effect a successful transfer. Mr B says he attempted the transfer again after the 7 February 2025 final response letter but that this failed. He does not provide evidence of this, but assuming he did attempt the same transfer from Fineco to Barclays, plainly this would not have succeeded because of the account holder symmetry requirements mentioned by Barclays in its final response letter. Regarding the further attempt at the transfer from Barclays to Degiro, it’s unclear why this was not able to go through. Regardless, even if Mr B was continuing to have issues with the transfer after the final response letter for which Barclays was responsible, I am satisfied that eventually the matter would have been resolved and the transfers would have gone through. Whilst I accept that Mr B had waited an unreasonably long time for the transfers, longer than would be expected based on industry standards, unfortunately that does not mean it was reasonable to take steps that would incur him significant financial loss. That would be the case even if Mr B had to wait a little longer than he already had to make the transfer. Further, Mr B has stated that his losses were caused in part because during the transfer process, he was specifically told by Barclays not to transfer the shares. However, I don’t consider this to be investment advice for which Barclays might have been held accountable. Rather, Barclays was likely here merely informing him that if he were to sell the shares during the transfer process this would naturally hinder that process and so whilst the transfer process was afoot the shares should be retained. This was information about process; this was not investment advice. Mr B could always have sold the shares if he decided he did not want to go through with the transfer. Thus, I don’t think Barclays’ comments regarding not selling the shares can make it in any way responsible for the financial losses Mr B claims. Mr B has also stated that had he known how long the process would take he would have instead sold the shares at the outset. However, when assessing redress, I would need to consider the position Mr B would have been in had Barclays acted correctly. In this case that means assuming the transfer completed within a reasonable timeframe – not that Mr B would have chosen to sell the shares instead. In any event, Mr B’s claim is speculative and would not form a reliable evidential basis for intent. It is also contradicted by his own actions, given Mr B chose to hold on to the shares for several months instead of selling them. Further, even when he did sell them, he then chose to repurchase them from the Degiro account. This all suggests he likely would have retained the shares. Mr B has also claimed that he was charged management fees from Barclays in respect of the in specie transfers, which would not have been charged if the delay had not occurred. Mr B has not provided any clear evidence to support this claim or sufficient details as to the nature of these fees, but I note that Barclays’ website indicates that Barclays does not charge management fees for in specie transfers. As such, at present at present I am not satisfied Mr B was charged such fees from Barclays and so I cannot consider any redress in respect of this.

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Mr B has additionally suggested a data privacy breach when Barclays erroneously sent Degiro a list of the shareholdings in Fineco that were to be transferred to Barclays, instead of the list of the shares already in Barclays that were to be sent to Degiro. I should explain that it isn’t within my remit to decide whether Barclays breached UK data protection legislation such as the UK GDPR – that’s a matter for the Information Commissioner’s Office. However, DISP 2.3.1 requires me to take into account what’s fair and reasonable in all the circumstances and in doing so I can take the relevant law and good industry practice into account. The law clearly places obligations on firms not to disclose personal data to third parties without an appropriate basis. Whilst I am not making a legal finding under data protection legislation, I have considered those obligations as part of assessing the fairness of Barclays actions in carrying out the regulated activity of administering and transferring Mr B’s shares. On the evidence available (Barclays has accepted it unnecessarily disclosed the wrong list of shares to Degiro) it appears Mr B’s personal information (i.e. the details of his shareholdings in Fineco) was disclosed to a third party (Degiro) without a clear or justified reason – and in the context of a regulated service, I consider that to be unfair. This failing is accounted for in my distress and inconvenience analysis below. Whilst I don’t think Mr B is entitled to compensation for financial loss, I do think he is entitled to compensation for the distress and inconvenience he has suffered. Barclays delayed Mr B’s requested transfers quite considerably due to a combination of (i) providing incorrect information and not identifying it sooner, (ii) operating under erroneous assumptions and (iii) not properly effecting or understanding Mr B’s clear instructions. In addition, as mentioned, it also unnecessarily and inappropriately disclosed Mr B’s personal financial information to a third party in Degiro. Mr B had to chase this matter over several months and he has recently provided this Service with a call log showing just how many calls he had to make as he attempted to resolve the transfer issues (the number of calls is quite significant). It is clear that he has suffered significant distress and inconvenience over a prolonged period of time and so therefore I think his compensation for that distress and inconvenience should be increased from £350 to £550. Since the above-mentioned provisional decision, we have received no response from Barclays. Mr B has responded contesting the decision. He made several points and clarifications (as alluded to above), including the following: • He clarifies that the Fineco shares that he intended to transfer to Barclays were ultimately transferred to Trading 212 well before the 31 March 2025 deadline and were not sold. Further, that it was Mr B’s shares in his Barclays account that were in fact sold at an alleged loss, with the cash being transferred to Degiro and from there the shares being repurchased. • He provides more detail as to why he believes the Barclays to Degiro transfer likely would not have gone ahead and why selling the shares was therefore reasonable mitigation. • He claims Fineco informed him that they may “dispose” of his shares after the 31 March 2025 deadline. • He provides further arguments to support his claim that had he known of the delays in advance he would have sold his shares earlier and avoided any loss.

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• He further elaborates on his belief that he is entitled to compensation to cover management fees and adds further incidental costs he would like compensation for. • He also claims entitlement to additional compensation for what he considers is an additional data privacy breach. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having reconsidered this complaint and taken into account Mr B’s additional comments, I’m upholding the complaint in part. I’ll explain why. Whilst I have considered all the additional remarks and evidence Mr B has provided, I will not comment on all of it, as I considered much of it either (i) not material to the outcome, or (ii) not adding to what Mr B had already stated and which I had already addressed. For example, Mr B’s comments about the role of third parties (against whom he has not brought a complaint) connected to Barclays and alleged communication issues between the two (to which he devotes five paragraphs) is speculative and does little to advance his case. Additionally, some of it also contained what appeared to be new complaints which are not within my jurisdiction to consider at this late stage of the case (given that Barclays has not had a prior opportunity to consider them). Mr B clarifies that the Fineco shares he intended to transfer to Barclays were ultimately transferred in specie to Trading 212, and that it was instead the shares he held in his Barclays account that were sold (on 27 February 2025), with the cash transferred to Degiro and the shares subsequently repurchased there. This only reinforces my view that there was simply no need to sell the shares in his Barclays account and crystallise the losses he now claims. Mr B had explained that he was motivated to transfer those shares because he wished to keep administratively separate shares in his Fineco and Barclays accounts. However, once the Fineco shares had been transferred to Trading 212, that central justification fell away. Further, since the Fineco shares were no longer held with Fineco, there is even less of a basis to say that the 31 March 2025 Fineco service termination deadline had any material bearing on the timing of the sale of the shares in his Barclays account. Thus, I can see no justifiable reason for him to have incurred the loss he now claims. Further, I should add that Mr B’s wish to keep different tranches of shares administratively separate was a matter of convenience rather than necessity. There is no evidence that temporarily holding the shares within the same account would have caused him any detriment, nor that he would have been unable to distinguish between the relevant holdings by reference to transaction history, acquisition dates, or cost basis. Thus, even if there was a risk at any point of the shares in the Fineco account and the Barclays account being held together in the latter, I’m not persuaded that possibility alone would have created any genuine urgency which would have made selling the shares in the Barclays account a reasonable or necessary course of action. Mr B has now clarified that he did not attempt a further transfer after Barclays’ 7 February 2025 final response letter. As mentioned, he simply chose to transfer the remaining shares in his Fineco account to Trading 212. As for the proposed transfer of shares in his Barclays account, he clarifies that he had made a further attempt at that transfer a few days before Barclays issued its final response letter. He claims there were further communication issues between Barclays and Degiro that were affecting this further attempt (essentially Barclays claimed it had not received a transfer request from Degiro and the latter claimed it had sent

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the request), and this confirmed his belief that the transfer would not go through and so he claims he was ultimately justified in selling the shares as a reasonable act of mitigation. However, I am not satisfied at all that this is evidence that the transfer would not have gone through and that Mr B acted reasonably in selling his shares and crystalising the loss he claims. It is not clear that this is the same issue mentioned in the final response letter that was cited as holding up this transfer. Further, Mr B has cited no evidence that he attempted to resolve the alleged communication issue or have it investigated – he simply heard there was a communication issue, and without any real investigation decided to sell the shares. This is not evidence that the transfer would not have gone through (or that Barclays was necessarily at fault here) and I remain of the view that Barclays – a banking service provider that facilitates such transfers regularly - would eventually have effected the transfer. The critical point, however, is that even if there were continued delays, this could not justify his selling the shares and crystalising the claimed losses as there was simply no urgency or apparent need for it. Mr B now claims that he was told expressly by Fineco that after the 31 March 2025 deadline it may “dispose” of his shares. As he accepts himself, he has been unable to provide any evidence to back up this claim and, in the circumstances, I am inclined to rely on Fineco’s published material which confirms that in specie transfers would still be possible after the deadline. In any event, as alluded to above, any relevance of the Fineco deadline is essentially removed, in light of Mr B’s clarification that the Fineco shares were transferred to Trading 212 well before the deadline. Mr B has also provided what he considers more evidence to support his claim that had he known about how much time he would have spent trying to complete the transfers, he would have sold his shares much earlier and realised a profit. In support of this, he cites the share prices in late December 2024, which if he had sold at that point would have allowed him to realise significant profits. Aside from the fact that this does not affect the fundamental point that I must consider redress based on what would have occurred had Barclays completed the transfer in a timely manner, this only serves to buttress my conclusion that Mr B likely would have retained the shares regardless. This is because there was nothing stopping Mr B from selling the shares in late December 2024 if he so wished – he could have cancelled the transfer and sold the shares and in so doing realised a significant profit. But instead he chose to retain them. Mr B has clarified that when he referred to management fees in respect of the transfer, he was in fact referring to the monthly charges which are partially based on the value of the holdings in his Barclays account (and not a fee for the transfer). Mr B claims that if the transfer from Barclays had occurred in a reasonable time, there would have been less value in the account and so lower monthly charges. Mr B claims less than £8 for this. Similarly, Mr B now claims he should be entitled to £1.65 for postage costs he incurred in having to write to Barclays to ask them to cancel the transfer following the delays. I acknowledge Mr B may have incurred these costs. However, these are exceedingly small incidental costs, and, in my view, they do not warrant a separate award. The £550 I have directed Barclays to pay fairly compensates Mr B for the overall trouble and upset he experienced, and it reasonably encompasses minor out-of-pocket costs of this nature. Mr B has also referred to an additional alleged personal data breach where he claims Barclays also erroneously sent Fineco the list of Mr B’s shares in his Barclays account that were supposed to go to Degiro. Even if Mr B is correct here (and I am not accepting he necessarily is, absent more evidence) both incidents arose from essentially the same set of transfer instructions given to Barclays and formed part of the same overall administrative failings I’ve already assessed. The information disclosed was limited to lists of shares held in Mr B’s investment accounts, and it was only sent to firms with whom he had an existing

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relationship. I am satisfied that this did not cause any additional material distress beyond what I have already considered. So I don’t think it is proportionate to make a further award. The £550 I am already directing Barclays to pay would fairly reflect the overall impact of its errors, including the data handling issues. Putting things right For the reasons mentioned above, Barclays Bank Plc must pay Mr B £550 for the distress and inconvenience he has suffered (and includes minor incidental costs). My final decision My final decision is that I uphold this complaint in part and direct Barclays Bank Plc to put things right as I’ve set out above. To reiterate, whilst I refer above to Fineco, Degiro and Trading 212 who were involved in the background to the events, I am not making any findings about those firms. My decision applies only to Mr B and Barclays Bank Plc. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr B to accept or reject my decision before 25 May 2026. Zaib Malik Ombudsman

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