The fine, the largest ever retail banking penalty imposed by the FCA, was discounted 30 per cent as a result of Lloyds agreeing to settle at an early stage, reducing what would have been a £167.7 million fine to £117.4 million. In the period reviewed by the FCA, Lloyds Banking Group (LBG) assessed customer complaints relating to "in excess of 2.3 million PPI policies" and rejected 37 per cent of those complaints. The FCA said the bank had on one hand designed and implemented a policy for handling PPI complaints in line with FSA guidance, but had then issued further guidance to its PPI complaint handlers directing them to assume the bank's PPI sales processes were "compliant and robust, unless notified to the contrary". The FCA said this guidance was described to complaint handlers as the "Overriding Principle", which the FCA said "affected the judgement of complain handlers and "created the risk of a default assumption LBG had not mis-sold PPI".