It's a long time coming, but last week I got a phone call from UB. From their complaints escalation team. Apparently the agent I'd been dealing with (who was supposed to have sent me out a final position) referred me to them instead of issuing the letter. Anyway, they investigated and have agreed that although they weren't "legally obliged to notify me" of any missed payments at the time, shortly afterwards there was a legal obligation introduced.
In short they don't recognise a mistake on their side, but do recognise that I was very poorly treated, and that I had made a genuine effort to pay on time.
So they are removing my name from the ICB (via amendment) and offering me €750 in compensation! Jolly good show I'd have thought. Would the FSO penalise them more do you think? Are they running scared, or is this a genuine offer?