Barclays Bank Plc · DRN-5727154

The complaint Mr Y has complained about the investment advice he received from Barclays Bank Plc (‘Barclays’). He would like to be compensated for the losses he has suffered and has also experienced significant stress and frustration. What happened In early 2025 Mr Y received advice from Barclays and invested £1.65m into a Global Equity Portfolio via Barclays Discretionary Portfolio Management Service. Shortly afterwards he was offered the opportunity to invest into a structured product referred to as SN003-25. Mr Y says he was advised to use Barclays’ loan facility to invest into the latter, but the investment didn’t go ahead. Mr Y became dissatisfied with the advice he was given and complained to Barclays in March 2025. Barclays didn’t uphold Mr Y’s complaint. It said Mr Y had agreed not to go ahead with the structured product investment as the use of the loan facility and higher risk made it less attractive. Mr Y could have sold his Global Equity Portfolio if he had wanted but confirmed Barclays did have a minimum investment of £2m. The structured product had produced a better return than the Global Equity Portfolio, but this was because of market conditions and couldn’t be foreseen when the advice was given. Mr Y had experienced problems in his communications with Barclays which it was looking into. Mr Y wasn’t happy with the outcome so brought his complaint to the Financial Ombudsman Service. He said he suffered a financial loss as he couldn’t invest into the structured product he wanted to and he wasn’t able to diversify his investments as intended. He said Barclays failed in its duty to provide clear and transparent information about account restriction or make suitable recommendations based on his circumstances. Our investigator who considered the complaint didn’t think Barclays needed to anything more. Mr Y didn’t agree with the investigator. He said there was a fundamental disagreement about the phone calls he had with Barclays. He said a fair observer would interpret the communication about the lending facility as encouraging him to use it despite the minimal gain and risk. He was never advised of the £2m threshold at the outset for the Global Equity Portfolio and was clearly told he couldn’t sell his as he was below the minimum holding and directly affected his ability to fund the structured product. Mr Y asked for his complaint to be reviewed by an ombudsman, so it has been passed to me for 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. After doing so, I’ve reached the same conclusion as the investigator and broadly for the same reasons. I’ll explain why.

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In making his complaint Mr Y has complained that Barclays breached some of the Financial Conduct Authority’s rules and Principles. The Principles have a wide application and I have therefore considered all of Mr Y’s points with the Principles in mind as a relevant consideration throughout my decision as well as the rules. Global Equity Portfolio At the end of 2024 Mr Y became a client of Barclays Private Banking and he transferred funds of £2.09m. On 7 January 2025 Barclays wrote to Mr Y with the investment strategy that had been agreed. Its recorded Mr Y was a high net worth investor with net assets of £45m (mostly held in entrepreneurial shares). He was a high risk investor and was to use Barclays Discretionary Portfolio Management service. The investment objective was for growth with a time horizon of five years plus. On 10 January 2025 Mr Y agreed to invest £1.65m in Barclays Global Equity Strategy. This was a high risk investment whose aim was to achieve, over the long term, superior capital growth with a recommended minimum investment period of seven years. I can see from the Schedule of Fees that the minimum portfolio value for entry was £5m but Barclays said they waived this in the case of Mr Y because of his net worth and recent onboarding to its Private Banking. Mr Y says he wasn’t aware of this at the time of the investment. However, I can see that Mr Y emailed Barclays on 8 January 2025 further to the information sent and that; ‘My only question is regarding fees. Following my first call with the team I was sent the information attached. I suspect that the reason for the difference is that the amount invested is under £5m, but my understanding from that first call was that while the minimum amount was typically £5m, this minimum was being waived and that the fee schedule shared post-call would be applicable.’ Barclays responded to say; ‘Apologies for the confusion. We have indeed waived the minimum amount and your portfolio will be aligned to the >£5m fee schedule. Please find attached an updated Costs & Charges document reflecting the discounted annual management fee of 0.95% (+VAT).’ So, I’m satisfied Mr Y was made aware of the minimum investment of £5m and that it was being waived in his circumstances. Structured Product SN003-25 There was a call between Mr Y and his adviser (‘Ms K’) on 31 January 2025. Ms K’s phone notes record; ‘[Ms K] and [Mr Y] met on Microsoft Teams to discuss recent recommendation to invest £300k into SN003-25 [Ms K] ran through Suitability Letter, costs and charges, schedule of fees, factsheet and KIID which were sent as part of advice email As this is [Mr Y’s] first structured product investment, [Ms K] ran through how the product works, stating key risks and mechanics.

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[Ms K] highlighted rationale behind recommendation, [Mr Y’s] high risk profile, high risk strategy, objective of growth over the long term – this recommendation is aligned to this [Mr Y] happy to proceed and understands [Ms K] asked where the funds should come from – i.e. will he transfer in new cash from elsewhere to fund the trade [Mr Y] stated that his intention was to sell down part of the global equity portfolio to fund the trade – [Ms K] was not aware of this [Ms K] stated that we would typically not recommend selling down the global equity portfolio after such a short time frame given he has only been invested for 2 weeks. This is designed to be a very long-term portfolio held for 5+ years, as detailed in the advice send relating to this portfolio. [Ms K] also stated that given we waived the minimums for the portfolio when he invested, it would be difficult to manage the portfolio at quantums much lower than the current balance and so would not recommend the partial selling down of the portfolio. [Ms K] suggested one option, which had been discussed with [Mr Y] before, relating to securities backed lending. [Ms K] and [Mr Y] discussed the benefits / drawbacks of this – particularly the cost of the facility being 0.75% + base rate. [Mr Y] didn’t feel that the marginal benefit of investing in the structured product would provide sufficient compensation for the additional risk and cost of the lending facility – [Ms K] agreed and understood [Ms K] stated that she would leave this with him to think about, and [Mr Y] confirmed he would reach out to [Ms K] if he decided to go ahead with the recommendation. [Ms K] verbally confirmed she would take this call as confirmation to NOT proceed with the investment, unless [Mr Y] confirms otherwise. [Mr Y] seemed happy and understanding’ The call was followed up with a suitability letter. Barclays has been able to provide a recording of the suitability call which Mr Y has listened to and has provided some analysis of the call. He concluded that he was encouraged debt borrowing against his portfolio rather than Barclays clearly explaining the restrictions on accessing the equity investments directly. But having listened to the call I don’t agree with Mr Y and am satisfied he could have sold his portfolio if he wanted to but was advised against this for what I consider to be reasonable reasons. The call itself came about because this was the first time Mr Y had invested into a structured product and needed to be informed about the details. He had been provided with various documents giving that information prior to the call and the adviser ran through other details. After those were given – as outlined in the above phone notes – the adviser asked where the investment funds were coming from and Mr Y explained that he wanted to sell part of his equity portfolio. The adviser said she hadn’t been aware of this and wouldn’t recommended such a course of action as the equity portfolio was designed for the longer term. The securities backed lending line – a credit line secured against Mr Y’s portfolio – was in place but the adviser explained there would be additional risk and cost for such leveraged investment. As a result,

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Mr Y concluded that the reward wouldn’t be sufficient and so the investment wasn’t to go ahead. Mr Y had until 11 February 2025 to decide if he wanted to invest and could contact Barclays if he changed his mind. At the end of the call Mr Y sought more information about the credit facility and where else it could be used. Mr Y has said that while the adviser used the term ‘recommend’ he took this to mean he wasn’t allowed to sell the portfolio as it was below the threshold. But while the adviser referred to a minimum of £2m for the Global Equity Portfolio there’s no reference to him not being able to sell if he wanted to during the call. And when Mr Y invested into the Global Equity Portfolio it was on the basis it was for a minimum investment period of seven years – typical for equity based investments – and he had only invested a few weeks earlier. And Mr Y did have some experience as an investor so, he was aware of the longer term nature of the investment but that doesn’t detract from the fact there’s nothing to suggest he couldn’t have sold it if he wanted to. And I don’t agree with Mr Y’s assessment that when the adviser said she hadn’t realised Mr Y intended on selling part of his portfolio this implied Barclays expected him to use the lending line instead. I don’t find that the call was couched in that way. And I also don’t agree the credit line was framed as a solution to the liquidity problem which the adviser knew existed. It’s quite clear from the call – when the credit charges were gone through – the adviser understood why Mr Y may not have wanted to proceed as she referred to the additional risks and costs etc of leveraged investment. I can’t see any reference to a minimum investment of £2m prior to the above call, only £5m. But even if Mr Y had been told that at an earlier stage, I’ve seen nothing to suggest that he wouldn’t have gone ahead with his investment, and in the knowledge it was a longer term investment. And there’s nothing to show that Mr Y didn’t intend on remaining invested for that period – or didn’t have the financial capacity to do so – to have alerted Barclays to the situation. Overall, I’m satisfied Mr Y was made aware of the option of using the credit line if he had wanted to and that he wasn’t told he couldn’t sell down his Global Equity Portfolio – this was only a recommendation – and isn’t reflected in the documentation Mr Y was provided. So, he wasn’t prevented from investing into the SN003-25 product if he had wanted to – whether that be via the credit line or selling down his portfolio – so I don’t agree Barclays should pay him the difference between the performance of his Global Equity Portfolio and the notional performance of the structured product if he had invested. Suitability of SN003-25 Mr Y told us that in early 2025, as well as the Global Equity Portfolio investment of £1.65m, he also invested £450,000 into gilts (to pay a tax bill) so this suggests that Mr Y had invested all the funds he transferred to Barclays. Mr Y has said that when Barclays made the recommendation to invest into SN003-25 he was interested as this was a way to reduce his risk exposure and increase diversification, but Barclays didn’t ensure he had an appropriate way to fund it. I’ve reviewed Mr Y’s circumstances as recorded by Barclays in its Current Financial Circumstances document and signed by Mr Y on 2 January 2025. He held cash of £2.4m, had shares in a company he 25% owned valued at £40m and owned his own property worth £800,000. Mr Y earned £150,000 a year and his annual expenditure was £68,000. Of the funds invested Mr Y would need to withdraw £631,000 for a tax bill. Mr Y wanted to be treated as an Elective Professional in all the financial instruments listed excluding non- mainstream pooled investments. Mr Y hadn’t used advisory or discretionary investment

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services before but had frequently used execution only services so he had some investment experience. While I don’t have all the history of the account, Mr Y transferred just over £2.09m to Barclays and looking at the cash held amount of £2.4m Mr Y still held over £300,000 in cash which was the amount he was looking to invest. So, while Mr Y might not have had the funds in his Barclays account, the amount of cash he held suggests that he could finance this separately. But even if I am wrong about that, and I appreciate the payment of the tax bill may have used some of these funds, because of Mr Y’s high net worth status and overall financial circumstances, I don’t think it was unreasonable for Barclays to have concluded he may have had cash elsewhere that he might not have declared to Barclays. I’ve borne in mind Mr Y has said he was happy with the investment recommendation as it would have allowed him to diversify away from his current investments. So, in and of itself I don’t find Barclays recommendation of the investment opportunity was unsuitable as it was something he potentially wanted and I’m not persuaded Barclays could have known he wasn’t in a position to finance it from cash. Barclays bank app and website Mr Y has said he experienced ongoing technical difficulties making it impossible to properly monitor his investments and the contact section if its website wasn’t functional. He says Barclays failed in its duty to maintain technical systems for account management. In its response to the complaint Barclays said it had raised the issue with its IT team but in the meantime, it could share balances and reports on the portfolio via email so it offered a workaround. While I appreciate this must have been frustrating for Mr Y but there’s always the chance that technology can go wrong. But its clear Barclays took action when this was brought to its attention, so it was looking to address the issue and which I find a fair and reasonable response. Overall, I don’t uphold Mr Y’s complaint. I don’t find Mr Y was told he couldn’t sell his Global Equity Portfolio, nor do I find that Barclays was wrong to recommend the structured product to him as the records suggest he potentially had sufficient funds to invest. And I also don’t think Barclays did anything wrong in pointing out the credit facility that was an option and available to him. In conclusion I don’t find Barclays responsible for any losses Mr Y says he incurred when comparing the performance of his Global Equity Portfolio to that of the structured product. I appreciate Mr Y will be disappointed with the outcome to his complaint. It’s clear he feels strongly about it, and I’d like to thank him for the time and effort he has spent in bringing it. But I hope I have been able to explain how and why I have reached my decision. My final decision For the reasons given, I don’t uphold Mr Y’s complaint about Barclays Bank Plc. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr Y to accept or reject my decision before 17 April 2026. Catherine Langley Ombudsman

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