Our compliance check must find that the person has incurred a relevant penalty. This may be because the person or their agent tells us about the deliberate default during the check, or our own investigations uncover it.
So if a person makes an unprompted disclosure of a deliberate default before we have started a compliance check, we cannot publish their name even if all the other conditions are met. The compliance check did not find the deliberate default - the person told us about it.
When a person makes an unprompted disclosure of deliberate defaults we are likely to check that disclosure. Our check may find other deliberate defaults that the person did not tell us about.
If a person makes an unprompted disclosure of deliberate defaults and we start a compliance check that uncovers other deliberate defaults that meet the conditions for publication,
- we may publish the person's name and details of those other deliberate defaults, but
- we may not publish the person's name and details of the deliberate defaults they told us about before our compliance check started.
This is illustrated in the examples on the following page.