"The systems and controls breaches arose because the firm failed to ensure that there was consistency between the firm's systems and the terms and conditions," said the Central Bank.
"It is noted that although controls existed in respect of the review process, these controls were not effective and resulted in the overcharging occurring."
MBNA did report the error and refund their customers at the earliest opportunity but the Central Bank said the penalties imposed on MBNA reflected the importance the Central Bank placed on consumer protection and its requirements to have adequate systems and controls in place to prevent such mistakes from happening. Some would argue on the other hand though that the steep fees could encourage some to cover up similar mistakes in the future.
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