Halifax Share Dealing Limited · DRN-6259472

The complaint Miss F complains that Halifax Share Dealing Limited (‘HSDL’) failed to execute all the trades on the regular investment plan that she’d set up within her Self Invested Personal Pension (SIPP). She also states that they failed to inform her of the failed transactions. What happened Miss F set up a regular investment plan on her SIPP with HSDL. That instruction meant that each month, the consumer sets a fixed monetary amount to put into their chosen stock on the scheduled investment date. Those instructions and the trades that HSDL executed were: April 2025: Stock Amount requested Price of asset Amount invested Public Pol Holding Invest £50 £1.365 £49.14 iShares VII Plc Invest £437.50 £8.816 £431.98 Greatland Gold Invest £100 £0.1241 £99.92 Trojan Fund Invest £250 £5.6921 £250 Games Workshop Invest £100 £136.32 £0 May 2025: Stock Amount requested Price of asset Amount invested Public Pol Holding Invest £50 £1.3198 £48.83 iShares VII Plc Invest £437.50 £9.4771 £435.95 Greatland Gold Invest £100 £0.1495 £100 Scottish Mortgage IT Invest £100 £9.3155 £93.62 Trojan Fund Invest £250 £6.269 £250 Games Workshop Invest £100 £155.84 £0

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After the April and May 2025 transaction failures, HSDL state that they emailed Miss F to inform her that they weren’t able to fulfil her order in full. Miss F has explained that she never received that message. Shortly afterwards, Miss F decided to formally complain to HSDL. In summary, she said that she was unhappy that all of her trades hadn’t executed as she believed that there was sufficient funds in her account. She also explained that she didn’t believe HSDL had notified her about the failure of the investments or provided her with an explanation of why the trades didn’t go through. After reviewing Miss F’s complaint, HSDL concluded they were satisfied they’d done nothing wrong. Miss F was unhappy with HSDL’s response, so she referred her complaint to this service. The complaint was then considered by one of our Investigators. He concluded that HSDL hadn’t treated Miss F fairly and he also said, in summary: • Notification is critical because it allows the consumer the opportunity to respond and act, for example, by adding funds or manually placing trades to avoid being disadvantaged. • The expected behaviour of the system is that an automated email should be generated and sent to a consumer when an investment fails or there are any other issues with completing a request. • The terms of Miss F’s plan do clearly indicate that consumers are responsible for ensuring sufficient funds, but they don’t remove the requirement for the business to inform the consumer if a trade fails. • While he could not conclusively state that HSDL never sent the notifications, based on the absence of evidence and the consumer’s experience, the fairest outcome is to uphold the complaint. HSDL, however, disagreed with our Investigator’s findings. In summary, they said: • There is no evidence to suggest that a notification was not sent to Miss F on this occasion. • The correct contact details are held by HSDL for Miss F and there were no reported system problems in the relevant period to prevent this process. • They did not consider it reasonable that this service expect businesses to store generic failure notices such as these for a longer period than 30 days as it would not be sustainable or practical to do so. Our Investigator was not persuaded to change his view as he didn’t believe HSDL had presented any new arguments he’d not already considered or responded to. Unhappy with that outcome, HSDL then asked the Investigator to pass the case to an Ombudsman for a decision. After carefully considering what both parties had to say on the matter, I decided to issue a provisional decision on the case as I was minded to reach a different conclusion to that of our Investigator and not uphold Miss F’s complaint. This window aimed to give both parties the time to provide any further comments that they wished for me to consider before I reached a final decision.

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What I said in my provisional decision: I have summarised this complaint in less detail than Miss F has done and I’ve done so using my own words. The purpose of my decision isn’t to address every single point raised by all of the parties involved. If there’s something I’ve not mentioned, it isn’t because I’ve ignored it - I haven’t. I’m satisfied that I don’t need to comment on every individual argument to be able to reach what I think is the right outcome. No discourtesy is intended by this; our rules allow me to do this and it simply reflects the informal nature of our service as a free alternative to the courts. My role is to consider the evidence presented by Miss F and HSDL in order to reach what I think is an independent, fair and reasonable decision based on the facts of the case. In deciding what’s fair and reasonable, I must consider the relevant law, regulation and best industry practice. Where there’s conflicting information about what happened and gaps in what we know, my role is to weigh up the evidence we do have, but it is for me to decide, based on the available information that I've been given, what's more likely than not to have happened. And, whilst I appreciate this will come as a disappointment to Miss F, I’m not planning on upholding her complaint - I’ll explain why below. Before I do, I think it’s important to make a distinction here about the nature of the investments that Miss F instructed HSDL to purchase for her. Those investments, which I’ve set out in the tables above, were a mixture of both shares and unit trusts. When purchasing unit trusts, it’s possible to buy fractions of units, so, if a consumer wants to invest £100 into that particular investment, they’re able to invest the full £100. However, investing in individual shares works differently, that’s because HSDL are only able to purchase whole shares, so if a customer sets a limit of £100 to invest in one particular share, if that individual share costs more than the £100 limit that the investor has set at the time of the scheduled purchase, it means that HSDL can’t then convert that instruction into a market order. In April and May 2025, HSDL weren’t able to fulfil Miss F’s instruction in full. That’s because the regular investment plan is not a flexible sum based on the success of other trades. Miss F asked HSDL to purchase £100 worth of Games Workshop shares. That means HSDL are allowed to buy Games Workshop shares up to the value of £100 but they are not permitted to exceed that level. But as the share price at the time of the scheduled instruction was in excess of the £100 that she wanted to invest, HSDL couldn’t carry out her request. And as I’ve already explained, they can’t purchase partial shares and they’re not allowed to take money from elsewhere to make up the difference to enable them to purchase a whole share, as that would exceed the cap on the investment that she placed. Regular investment plans are designed to operate automatically and without manual intervention. They convert the customer’s monetary instruction into a market order only where it is possible to do so within the stated spending limit. Where the price of the selected share exceeds the limit set by the customer at the time of execution, the instruction cannot be actioned. This is normal behaviour for execution-only regular investment services and it’s not indicative of an error or system failure on HSDL’s part. I also think it’s relevant here to set out the nature of the relationship that Miss F has with HSDL. Miss F is an execution only customer and what that means in practice is that it’s up to her to decide how much money to deposit, which markets and when she wants to invest in, monitoring her account and determining when and how she should close her positions. It’s also Miss F’s responsibility to ensure that she has sufficient funds in her account in good time, to allow HSDL to action her instructions. And, importantly, it’s also her responsibility to be aware of the prices of the instruments that she wishes to purchase.

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The terms of an execution-only service are structured in such a way that means HSDL does not monitor share price movements on the customer’s behalf or provide alerts when a selected investment becomes unaffordable within the user-defined limit. In this context, it’s Miss F’s obligation to review her portfolio activity and ensure that her instructions remain viable. I’ve looked closely at Miss F’s chosen investments. Her April 2025 instruction asked HSDL to purchase five instruments and in May 2025, that altered to six. So, it seems to me that after the first Games Workshop purchase failed in April 2025, Miss F subsequently logged into her account and added a further, new instruction (for Scottish Mortgage), thereby missing an opportunity to identify the failed transaction from the previous month. Whilst I’ve explained that consumers operating an execution only account have a responsibility to monitor and oversee their own trades, that doesn’t absolve HSDL of keeping customers abreast of the trades that have and haven’t been undertaken. Miss F states that she never received confirmation from HSDL following their failure to purchase the Games Workshop shares in April and May 2025. However, HSDL say that they did send confirmation but don’t hold onto generic information emails for more than 30 days. In circumstances where there is conflicting or incomplete evidence about what occurred, I must decide on the balance of probabilities what is more likely than not to have happened. This involves weighing the plausibility of each party’s account in light of the available records, the firm’s usual processes, and any indirect indicators that help show what likely occurred. HSDL have shared copies of the investigation that their IT team have undertaken and unfortunately, they’ve explained that they’re unable to retrieve those messages. However, I do not consider there is persuasive evidence that the notifications were not sent. I also considered whether there were other indicators available to Miss F which would reasonably have alerted her that the instructions had not executed. In regular investment accounts, each successful trade generates a contract note. When a trade does not execute, no contract note is issued. This creates a clear and predictable pattern of communication that enables customers to identify which trades have completed. It appears more likely than not that Miss F received contract notes for the successful transactions so the absence of a contract note for the Games Workshop shares would reasonably have indicated to Miss F that the trade had not executed. In assessing this issue, I have taken into account that HSDL held the correct contact details for Miss F and that there is no evidence of a system-wide malfunction. Firms do not typically retain generic automated messages for long periods, and I do not consider the absence of archived copies, by itself, to be persuasive evidence that the notifications were not sent. Even if I had concluded that Miss F had not received notification of the failed trades, I would still need to consider whether that omission caused a financial loss that she would not otherwise have suffered. Here, the underlying reason the trades did not execute, namely, that the share price exceeded her stated investment limit, would not have been altered by earlier awareness. Miss F would still have been unable to purchase a whole share within the amount she had capped the instruction at. Accordingly, even on that alternative scenario, I am not persuaded that a compensable loss arose. Responses to my provisional decision: After considering what I had to say, Miss F stated, in summary, that she disagreed with the provisional decision. She said that HSDL had also rejected her trade instructions in June

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2025. She went on to say the situation that month was no different to April and May 2025. Yet in June 2025, she had to re-schedule the buy date because the whole trade failed. She also explained that she didn’t know the option to purchase fractional shares had been withdrawn. I requested further information from HSDL and on 25 March 2026, I wrote to Miss F to share that information. What I said: “Halifax have said that you were correct in your initial statement about the June 2025 purchases failing; the trades were initially set up for the first re-investment date of the month which was 5 June 2025, but that one didn’t execute. Halifax say that you then made changes to the investment plan on 10 June 2025 which were dealt on the 17 June 2025. I understand that your planned purchases prior to the change made on the 10 June 2025 were: • £100 – into Games Workshop • £250 - into Trojan Fund • £200 - into Scottish Mortgage Trust • £50 - into Public Policy Holdings • £437.50 - into IShares VII PLC ETF • £100 - into Greatland Gold This totals £1,137.50, however, Halifax say that you had a settled cash balance of £1053.37 on the investment date which fell short of the required amount. So, when the system ran the overnight fund checks to ensure ‘sufficient cleared funds’ were available, it identified there was not and so wouldn’t proceed to schedule the investments for the following morning which Halifax tell me is the correct course of action. Importantly, Halifax say that this wasn’t a scenario encountered in the months prior or after because your settled cash balance was sufficient to pass the fund checks so that the overnight orders could be created. Having considered Halifax’s response to my provisional decision, I’m satisfied that their explanation fairly and accurately distinguishes the reasons why the June 2025 transactions did not execute, in contrast to the April and May 2025 trades which did proceed where possible. In April and May 2025, the only transactions that failed were the attempted purchases of Games Workshop shares, and these did not execute because the share price on each scheduled trading date exceeded your £100 investment limit, meaning Halifax could not convert the instruction into a market order or purchase fractional shares. In June 2025, however, the position was different: the collective value of your standing investment instructions (£1,137.50) exceeded your settled cash balance available on the investment date (£1,053.37). As a result, the system correctly identified insufficient cleared funds during the overnight checks and did not schedule any of the trades for execution. This scenario didn’t arise in the previous months, when sufficient cash had been available for the system to create the automated orders. Halifax have also confirmed to me that they did previously provide customers with the opportunity to purchase fractional shares, but that offering was withdrawn some time ago.

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Based on all of the information now available, I’m not minded to change the outcome of my provisional decision. However, before I finalise the case, please would you be kind enough to let me know within the next five days (so, by Monday 30 March 2026) if you have any final comments you’d like me to consider, or if you’re happy to confirm that you agree with my findings.” Miss F responded to my comments on 26 March 2026 explaining that she still disagreed with the outcome. She also said, in summary: “Multiple follow-ups were required to obtain complete responses from Halifax, and even then, information was only provided in stages. While I appreciate that you have actively chased this, the delays caused by Halifax form part of the overall customer experience and should be considered when assessing whether I have been treated fairly. The final explanation from Halifax may have fairly and accurately distinguished what happened, but it has taken the best part of a year to get to this point. I did not have this level of clarity when I phoned the service in June 2025. Secondly, and more importantly, I do not believe Halifax’s process was sufficiently clear or transparent. The explanation that all transactions would fail if there were insufficient cleared funds at the point of overnight checks was not made clear to me at the time. This is a critical point, as it directly contradicts the reasonable expectations created by previous months’ activity. In April and May 2025, transactions were partially executed where possible, with only specific trades failing due to price constraints. This established a clear expectation that instructions would proceed on a best-efforts basis rather than being treated as an “all-or- nothing” process. In June 2025, however, the entire set of transactions failed due to a shortfall in the total available balance. There was: • no clear prior explanation that this different approach would apply; • no warning that all trades would fail rather than partially complete; and • no opportunity provided to address the shortfall before the trades were cancelled. In addition, I was not notified at the time that the trades had failed due to insufficient cleared funds, which meant I was unaware that my investment instructions had not been carried out. Halifax stating that purchasing fractional shares were discontinued some time ago was not made clear to me in my phone call with Halifax in June 2025 and the time span "some time ago" is neither clear or precise. Should I expect to be notified of the discontinuation of this service? The service falling below standards expected occurred some time ago now. I'm not sure how much more time they are talking about. Given these points, I do not believe it is fair to conclude that Halifax acted reasonably simply because their internal process operated as designed. The key issue is whether that process was sufficiently clear and aligned with the reasonable expectations of a customer, which I do not believe it was. For these reasons, I ask that my complaint be upheld. I believe the lack of transparency, combined with the inconsistent customer experience and the delays in resolving this matter,

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justify a finding in my favour, along with appropriate compensation for the inconvenience caused.” 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. I do accept Miss F’s point that HSDL’s final explanation now accurately distinguishes what happened between the April, May and June 2025 trades, and it has taken some time to reach this point. However, for me to be able to uphold her complaint, I would need to be satisfied that HSDL had failed to execute her instructions as a consequence of an error of their making, but that threshold hasn’t been met. Miss F says that, because some instructions were partially executed in April and May 2025, she expected the same approach to apply in June 2025. However, as I’ve already set out above, the evidence shows that the April and May 2025 failures were caused solely by the price of a single instrument exceeding her investment limit, meaning those instructions could not convert into a market order. But, in June 2025, the situation was materially different, that’s because the total value of all of her planned instructions exceeded her settled cash balance during the overnight fund check, so no trades could be created at all. While I accept that this distinction may not have been clear to Miss F at the time, the difference arises from how regular investment plans function, rather than from an error by HSDL. Miss F also raised concerns about the clarity of communications, including the lack of a timely explanation about why all of June 2025’s trades initially failed and whether fractional share purchasing was still available. I agree that clearer communication from HSDL at the time would have likely reduced the confusion here. However, even if the notifications had been received, or if the explanations had not been delayed or incomplete, this would not change the underlying reasons of why the trades didn’t execute. In April and May 2025, the share price exceeded the spending limit; in June 2025, there were insufficient cleared funds at the relevant point in the process. These factors, not the communication issues were the immediate causes of the failed instructions, and communication shortcomings alone do not give rise to a compensable loss in this instance. I’ve also considered Miss F’s concerns about the time taken to obtain complete information from HSDL. I recognise that the delays and the need for multiple follow-ups with HSDL were inconvenient and understandably frustrating. While I do not minimise that experience, delays in complaint handling do not, in themselves, demonstrate that HSDL acted unfairly when executing the original investment instructions, nor do they alter the technical reasons why the transactions did not proceed. As my role is to decide whether the firm acted incorrectly in carrying out the instructions at the time, I cannot base an upheld finding solely on subsequent delays in clarification. Miss F also expressed concern that she was not made aware that fractional share purchases had been withdrawn. However, HSDL say that this feature was withdrawn some years back. However, under an execution-only relationship, consumers are responsible for reviewing the available features and checking affordability and limits before placing their instructions. For these reasons, HSDL’s withdrawal of the fractional share purchase offering doesn’t change the outcome of the complaint.

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Having considered all of Miss F’s latest comments alongside the full evidence available, I remain satisfied that HSDL did not fail to execute her instructions due to any error on their part. While I acknowledge the communication issues and the frustration they caused, they do not alter the technical reasons why the trades did not go ahead, nor do they amount to unfair treatment under the circumstances. So, it therefore follows that I’ve reached the same conclusion that I set out in my provisional decision and subsequent message to Miss F above. My final decision I’m not upholding Miss F’s complaint and it therefore follows that I won’t be instructing Halifax Share Dealing Limited to take any further action. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss F to accept or reject my decision before 24 April 2026. Simon Fox Ombudsman

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