Barclays Bank Plc · DRN-6171757

The complaint Mrs C complains Barclays Bank Plc (‘Barclays’) delayed her ISA transfer. What happened Mrs C had a stocks and shares ISA with Barclays. She wanted to transfer cash that was in it to an ISA with a new provider. Below I’ve summarised the events that followed. Although I haven’t mentioned everything here, I’ve reviewed all the evidence. I’ve limited my summary to the facts most relevant to my decision. On 20 May 2025 the new provider wrote to Mrs C that Barclays required a signed form to process her transfer request. It enclosed a transfer request form and asked her to check the details, complete the form and send it back within five working days. It said the ISA transfer had to be done within 15 working days of receiving the completed transfer request form. On 24 May 2025 Mrs C signed the form. It requested the cash be transferred to ‘Barclays Investment Solutions Limited ISA’. It said ‘I authorise my existing ISA provider to transfer the ISA (account number above) to [the new provider] …’ The new provider stamped Mrs C’s form as received on 28 May 2025. And on 28 May 2025 it posted a letter to Barclays, enclosing the transfer request form and asking Barclays to carry out the transfer. The letter was addressed to Barclays Investment Solutions Limited at an address in Glasgow. On 13 June 2025 the new provider wrote to a Barclays email address saying it had sent an ISA transfer request to Barclays by post last month and hadn’t received a response. It quoted a 10-digit reference number which was Mrs C’s Smart Investor ISA number. On 16 June 2025 Mrs C called Barclays for an update on the transfer. Barclays said it had no transfer request on its system. It gave Mrs C an email address to pass on to the new provider so it could send the transfer request there if it hadn’t already. Mrs C asked if Barclays could do that itself, but it said it wouldn’t usually do that. But it said it would check internally whether it had received any communication from the new provider which might indicate what had happened to Mrs C’s request. Mrs C agreed to contact the new provider. She said she expected the transfer to be done soon because Barclays had to complete it within 15 days. Barclays said it couldn’t do that because it didn’t have the transfer request yet. And Mrs C submitted a complaint. Barclays asked Mrs C how the new provider sent the request. Mrs C said Barclays sent Mrs C a form to sign and she sent that back to the new provider who sent it to Barclays. Barclays said the form would’ve come from the new provider but Mrs C disagreed. Barclays asked where the new provider sent the form and Mrs C said she didn’t know and it would’ve been to an address Barclays had provided. On 17 June 2025 Barclays called Mrs C about the transfer. Mrs C said she’d spoken to the new provider. It hadn’t sent the transfer request by recorded delivery but would do so that day. It had posted the request to an address in Glasgow which Mrs C said Barclays had

-- 1 of 7 --

given to the new provider. Mrs C had now given the new provider the email address Barclays had given her, but the new provider didn’t know if it could email the transfer request so it would send it by post. Barclays said the email address was the one it always used for ISA transfers and it would reply to the new provider using that address, so it was OK for the new provider to send the transfer request to that email address. Mrs C said her complaint was that Barclays shouldn’t be using forms because they were antiquated and using them meant relying on post, and Barclays must have some record of her ISA transfer because the new provider had been given a form by Barclays and sent it to a Barclays address. She said she was losing money every day and might miss out on the interest rate she wanted. Mrs C also told Barclays she had a medical condition. Barclays said an ISA transfer request only appeared on its system if Barclays received a signed transfer request form. Also on 17 June 2025 the new provider sent Mrs C’s transfer request form to the email address which Barclays said was the one it used for ISA transfers. On 18 June 2025 a different Barclays team emailed the ISA transfer team and said it didn’t need to be included in any further emails about Mrs C’s transfer. It said it dealt with different types of accounts which could be identified by the fact that they had only 9 digits. On 19 June 2025 Mrs C called Barclays saying the new provider had told her she’d supplied an incorrect account number. On 26 June 2025 Barclays transferred the cash out of Mrs C’s ISA. It notified the new provider by email. The cash arrived in Mrs C’s ISA with the new provider on 27 June 2025. On 8 July 2025 Barclays replied in writing to Mrs C’s complaint. In summary it said the following: • Barclays wasn’t responsible for delaying the ISA transfer. • The new provider posted the transfer request form to the wrong department of Barclays and wrote to the wrong email address. That caused the delay Mrs C had experienced. • Barclays usually allowed 10 working days to redirect misdirected requests to the correct department. And those 10 working days would be in addition to the 15 working days that ought reasonably to be allowed for a cash ISA transfer. So if documents were received on 28 May Barclays would expect to discover them by 11 June and then to complete the transfer by 2 July. So despite the delay caused by the misdirected form, Barclays had achieved the transfer within its own timescales. • Mrs C wanted to be able to send her request to Barclays direct, but the transfer request form had to come from the other ISA provider. • Barclays didn’t, as part of its process, speak to new providers on behalf of customers. • Barclays wouldn’t compensate Mrs C for any missed interest because it wasn’t responsible for any delay. • A form being sent to Mrs C and signed by her indicated an intention to transfer, but until Barclays received the signed transfer request from the new provider it wouldn’t log the transfer on its system.

-- 2 of 7 --

• The reason for confusion over the number of digits in Mrs C’s account number was that the new provider sent the form to the wrong department and that department used nine-digit account numbers whereas Mrs C’s account had 10 digits. • Mrs C said Barclays wouldn’t facilitate a transfer electronically, but Barclays preferred electronic contact. Mrs C wasn’t satisfied. She referred her complaint to this service. She said she’d applied for the transfer on about 15 May 2025, but the transfer wasn’t done for several weeks, so she called Barclays who said it had no record of her request. The new provider sent the request again but the transfer still wasn’t done for several weeks. She said Barclays incorrectly told the new provider that her account number was wrong so Mrs C had to call Barclays again. Mrs C said her complaint was that Barclays should not require her to sign a form for an ISA transfer, it should’ve had a record that it had issued the form, it should’ve been more helpful, and it had taken well over 15 days to complete the transfer. One of our Investigators looked into Mrs C’s complaint. She didn’t think Barclays had acted unfairly. In summary she said the following: • Mrs C might have contacted Barclays in May 2025 about transferring, but for Barclays to have processed a transfer it required a clear and actionable request from the receiving provider. The usual process for ISA transfers was that the receiving provider would contact the transferring provider and that would initiate the process. • Many brokers required paper-based instructions and it wasn’t compulsory for them to do otherwise. This often happened when the brokers involved didn’t have systems that worked together which was the case here. • Barclays said it preferred to communicate by email and would normally expect to receive a transfer request form by email (where the transfer couldn’t be done via a shared electronic system). The new provider’s responses to the investigator’s queries didn’t indicate that Barclays had asked the new provider to send the form by post. • The transfer form Mrs C was given to sign appeared to have been created by the new provider, not by Barclays. • The new provider found the wrong address for Barclays and posted the form there. • If Barclays received the form in the wrong department it should’ve forwarded it to the correct department in reasonable time. But Barclays said it didn’t have the form and there was no evidence it was received. And it was the responsibility of the receiving provider to ensure the transferring provider received the transfer request. • The investigator couldn’t recommend Barclays compensate Mrs C for things that weren’t its fault. Barclays had apologised to Mrs C for the distress she experienced and that was sufficient in the circumstances of the case. Mrs C disagreed with the investigator’s view. She reiterated the following points: • If the form was sent to the wrong address within the Barclays business, Barclays should’ve redirected it to the right place in reasonable time. • Barclays knew about Mrs C’s transfer request and should’ve had a record of it. What she’d communicated to Barclays wasn’t just her ‘wishes’; it was her instructions.

-- 3 of 7 --

• Mrs C had an online conversation with Barclays on 25 May 2025 about how to transfer and Barclays didn’t say it would need a signature. • Barclays shouldn’t have said her account details were incorrect when they were not. The form clearly had all the correct details on it. • If the transfer request form could’ve been emailed in the first instance, why did Barclays ask the new provider to post it? • Barclays did nothing to help sort things out in a reasonable timeframe. • Barclays denied knowing that it had sent out a form. Because no agreement could be reached, the complaint was passed to me to review afresh and make a decision. 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 done so, I’m not upholding the complaint. I’ll explain why. The purpose of this decision is to set out my findings on what’s fair and reasonable, and explain my reasons for reaching those findings, not to offer a point-by-point response to every submission made by the parties to the complaint. And so, while I’ve considered all the submissions by both parties, I’ve focussed here on the points I believe to be key to my decision on what’s fair and reasonable in the circumstances. If I haven’t mentioned something here it doesn’t mean I haven’t considered it. I want to be clear here at the outset that in this decision I’m considering the actions of Barclays only. Barclays is the business Mrs C has complained about here. Although I’ll mention things done by the new provider, I’m not making any findings about the new provider. Mrs C raised many points of dissatisfaction with Barclays in this case, but at the centre of her complaint is the time taken for her ISA transfer to complete. She intended to invest her money into a savings product with a fixed rate of interest and she was understandably concerned that while she waited for the transfer to happen she was missing out on interest and she might miss out on the fixed rate altogether. Government guidance for ISA transfers says transfers between two cash ISAs should usually be done in 15 working days from the date the new provider receives the signed transfer form at its registered office. All other transfers should usually take no more than 30 calendar days from that date. These timeframes are guidelines only, not strict legal requirements. But they set a benchmark for what can be considered reasonable. Although Mrs C sought to transfer only the cash portion of her ISA assets, her transfer was from a stocks and shares ISA. So the relevant guideline was 30 calendar days. Mrs C’s new provider received her completed transfer request form on 28 May 2025 and the cash arrived in her ISA with the new provider on 27 June 2025. So the overall transfer time didn’t exceed 30 calendar days from the date the new provider received the signed transfer form at its registered office.

-- 4 of 7 --

As I’ve said, the guidelines aren’t strict requirements. And they don’t mean that a business shouldn’t complete a transfer more quickly if it’s reasonably possible to do so. In this case, because the transfer form was misdirected by the new provider, I don’t think it’s reasonable to expect Barclays to have transferred the cash significantly sooner than it did. I understand that Mrs C says Barclays was responsible for the delay, including by requiring her signature and requiring the form to be posted and by providing an incorrect postal address. But having looked at everything carefully I don’t agree. I know Mrs C was frustrated by various aspects of the process, including that Barclays required a signature from her and that the transfer couldn’t be done entirely online, and that before receiving the transfer request form Barclays didn’t record her request to transfer and wouldn’t take any steps to carry out the transfer. I’m sorry to disappoint Mrs C, but I can’t say any of that was unreasonable on the part of Barclays. Mrs C has said Barclays ought to have acted earlier rather than waiting for the transfer form before beginning the transfer. I know she gave an indication to Barclays in May 2025 that she was planning to have the ISA transferred when she contacted Barclays to ask for some information such as what account number to use. But it’s set out in the relevant regulations and reiterated in government guidance that an ISA transfer is initiated via an application from the customer to the new provider. So Mrs C’s enquiries to Barclays didn’t give Barclays a basis to begin the transfer even if it did show to Barclays what she was planning to do. Also, a business like Barclays is likely to receive many enquiries from customers about transfers that might or not might subsequently don’t go ahead. In the absence of formal authorisation from Mrs C, it wouldn’t be reasonable for Barclays to begin transferring her assets on the assumption that she would go ahead with the transfer. And without a transfer request coming from the new provider, Barclays couldn’t know whether the new provider agreed to receive the transfer. It’s important that a customer’s assets aren’t moved without the agreement of both parties. For all of these reasons I can’t say Barclays treated Mrs C unfairly by not beginning her ISA transfer before it received a request from the new provider. When Mrs C called Barclays and said the transfer request form had been sent, Barclays was reasonably helpful. With the information it gave her, Mrs C was able to help the new provider send the form to the correct email address for Barclays. And it did so very soon afterwards. I understand Mrs C would’ve preferred Barclays to contact the new provider itself. But by enabling Mrs C to resolve the issue Barclays acted in line with the ISA transfer process which puts the onus on the receiving provider to initiate the transfer and to follow up if it receives no reply. I understand Mrs C disclosed to Barclays a medical condition and associated distress she was experiencing. I sympathise with Mrs C on this point. But I think Barclays helped her appropriately by giving her an email address to pass on to the other provider which was successful in moving things along. Mrs C had called Barclays to chase things up, and so it’s not unreasonable that Barclays thought she could pass on an email address to the new provider. Although Mrs C had been upset by the delay up to that point Barclays hadn’t known about that and so couldn’t have helped any sooner. And so – and because I’m satisfied it was generally appropriate for Barclays to enable Mrs C to resolve the delay – in the particular circumstances of this complaint Mrs C’s medical condition doesn’t give me cause to say Barclays treated her unfairly. Mrs C mentioned that when she contacted Barclays on 25 May 2025 about how to transfer the ISA Barclays didn’t tell her a signature would be required for her transfer request. But I haven’t seen that Mrs C gave Barclays any reason to think she needed to be told that particular bit of information. And if Barclays didn’t mention it to her in those circumstances that doesn’t mean it was unreasonable for Barclays to require a signature. Government

-- 5 of 7 --

guidelines explicitly allow ISA managers to require a signature, and I don’t think it’s an unreasonable request where the transfer is being done manually via a form as this one was. Mrs C has complained that Barclays shouldn’t have required a form because doing so was antiquated and caused delays by relying on the post. Again I don’t find that Barclays is at fault here. Government guidelines say the new provider can ask the customer to authorise the transfer by asking them to complete one of the following: • ‘a transfer authority form (which is not a requirement of the ISA regulations), which the new ISA manager forwards to [the transferring provider] and authorises [the transferring provider] to transfer the ISA (or part of it) to them • an ISA application form or a transfer instruction’. In many cases the customer can give a transfer instruction online and the ISA process can be done through an electronic gateway. In this case the new provider asked Mrs C to complete a transfer authority form and it said it couldn’t do the transfer electronically. When a transfer can’t be done electronically that’s usually because the two providers don’t use a system that gives them a shared electronic gateway. The fact that in this case Barclays and the new provider didn’t use the same system isn’t a fault on the part of Barclays. Guidelines allow for manual transfers. It’s also important to note here that the manual transfer didn’t have to be done by post. As Barclays said, its preference was for email, and it accepted Mrs C’s transfer request form by email. Mrs C said Barclays told the other provider it had to use post and it gave the other provider the transfer request form to be completed and the postal address for sending the form. I don’t doubt Mrs C’s sincerity or her conviction on these points, but I’ve seen no evidence that Barclays did these things and I think it unlikely that it did them. Given that Barclays preferred email and didn’t use post itself, and given that the postal address used wasn’t the correct one for the Barclays transfer team, I’d need to see some evidence if I were to conclude that Barclays had requested a form be sent by post and that it be sent to the address that the new provider used. In responding to queries from this service the new provider didn’t send any evidence showing Barclays had told it to post the form or where to post it. And the new provider indicated that the form Mrs C completed was a form that belonged to the new provider (not Barclays). The structure of the form itself – which, for example, names the new provider in the customer declaration – adds to my impression that the form belonged to the new provider, as does the fact that under the guidelines it wasn’t the role of Barclays to provide a transfer form to Mrs C when she was transferring away from Barclays. Moreover I’ve seen no evidence that there was any communication at all between Barclays and the new provider before the new provider sent Barclays a transfer request form. So I think there’s been some misunderstanding here. And I can’t conclude that Barclays was responsible for the form itself or the posting of the form. Mrs C said Barclays shouldn’t have said the account number she provided was incorrect. As I understand it a separate department of Barclays had become included in the correspondence due to the transfer request form having been sent to a wrong address. That department pointed out that Mrs C’s account couldn’t be linked to that department because of the number of digits in the number. I can see there was some confusion over this amongst the parties, but I don’t have reason to say that what Barclays said about account numbers was incorrect. It didn’t say Mrs C’s account number was wrong. It said the digits in Mrs C’s account number showed that the form had been sent to the wrong team. Overall I’m sorry to know Mrs C found the transfer process stressful. I do understand her frustrations. But I can’t conclude that Barclays treated her unfairly and so caused her

-- 6 of 7 --

detriment that must be put right. And so I’m not requiring Barclays to do anything on this occasion. My final decision For the reasons I’ve set out above, my final decision is that I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs C to accept or reject my decision before 27 April 2026. Lucinda Puls Ombudsman

-- 7 of 7 --