Financial Services Bill

Baroness Drake Excerpts

Monday 11th June 2012 Lords Chamber

[Baroness Drake]

My Lords, the Bill replaces the tripartite system with a twin-peak model, but the witnesses to the Joint Committee of which I was a member were overwhelmingly of the view that the structure of financial regulation was not the determining factor in how successful a country was in handling a crisis. The chairman of the European Banking Authority said that,

“during the crisis there were different types of construction that equally succeeded or failed in the face of the crisis”.

In many other countries the philosophy was a presumption that markets act rationally. The IMF Global Financial Stability Report stated in April 2006 that,

“the dispersion of credit risk by banks to a broader and more diverse group of investors, rather than warehousing such risk on their balance sheets, has helped make the banking system and overall financial system more resilient”.

To repeat Her Majesty the Queen’s question: why did no one see it coming? Clearly in 2006 the IMF did not appreciate the underlying fragility and interdependence of the financial system.

As other noble Lords said, successful regulation depends less on the structural route taken and more on the regulatory culture, focus and philosophy. Controlling inflation and excesses in the financial system will require informed decisions that from time to time will be unpopular. That is a powerful argument for granting greater independence to the regulator to make informed rational decisions. Under the Bill, the Bank and the governor will acquire unprecedented new power. The granting of independence must be proportionate to the democratic authority vested in both the Government and Parliament. As Sir Mervyn King conceded in his 2012 “Today” programme lecture, when referring to the new powers:

“Independence is … not the discretion to do as you wish, but the exercise of specific powers delegated to us by Parliament to meet a remit set by Parliament”.

With independence come the responsibilities of transparency and accountability. My concern is that the Bill does not yet sufficiently address those responsibilities. For example, it provides for the Bank to notify the Chancellor when there is a material risk to public funds, and for the Chancellor to be responsible for decisions in a crisis involving such funds. It is important that the Bill gives a high level of confidence that this requirement for the Bank to notify the Treasury is set at a sufficiently low level that there should be no surprises, and there must be no ambiguity as to how and when authority transfers from the governor to the Chancellor.

The memorandum of understanding between the Treasury and the Bank details the process by which the judgment of materiality will be made, not the definition. The Government argue that giving a strict definition of material risk runs counter to the emphasis on judgment. While this argument has some merit, memorandums of understanding are easy to change and lack authority. Similarly, this House should satisfy itself that there is a high level of confidence which will not be thwarted by disputes between the Treasury and the Bank and that the Chancellor has sufficient powers to direct the Bank in a crisis—for there will certainly be future crises—but we know that the chair of the Treasury Select Committee has expressed his concern that the Bill currently grants powers to the Chancellor that are too circumscribed.

To fulfil its responsibilities, the Financial Policy Committee will have an armoury of powerful macroprudential tools, which Parliament should scrutinise through an enhanced affirmative procedure, to allow for consideration by Select Committees and for the Treasury to consider their recommendations. The Financial Secretary resisted such an enhanced procedure on the ground that,

“one must ensure that the degree of scrutiny is proportionate to the powers that are being engaged in”.

Macroprudential policy enters uncharted waters and gives the FPC significant powers. I struggle to understand how the enhanced procedure is disproportionate in those circumstances.

The draft Bill enshrined the principle of consumer responsibility but did not place an equivalent responsibility on firms. The Joint Committee recommended that the Bill,

“place a clear responsibility on firms to act honestly, fairly and professionally in the best interests of their customers”.

The Government subsequently inserted a new principle, to which the FCA must have regard, that,

“those providing regulated financial services should be expected to provide consumers with a level of care that is appropriate”.

However, that does not provide a sufficient level of protection for consumers. It leaves too open the key question of what is an appropriate level of care.

The case for complementing the principle of caveat emptor with a duty on firms is compelling. We currently have systemic inequalities of knowledge and understanding and misaligned interests between consumer and provider, with the consumer consistently the loser. Confidence in financial products has been worn down by mistrust. Professor Kay recently observed that better performing companies are ultimately the only thing that generates long-term value for savers. However, this alignment is getting lost in an ocean of intermediation, where conflicts of interest and complex and high charges exist. The chain of intermediaries in the savings and investment market is increasing.

While there are new features in the Bill to be welcomed, the current framework still limits the ability to address such problems. Perhaps I may illustrate by reference to pensions. The asymmetries of information are well understood, as are the reasons to believe that financial education, however worth while, will never get us to a position where most consumers are capable of making rational decisions about long-term savings. Indeed, auto-enrolment, which will put millions of ordinary people saving in capital markets, is based precisely on that behavioural insight: it takes key decisions out of the hands of the saver altogether. Employers, as now, will make the big decision about which provider to choose. Consumers will save not because they have carefully weighed the costs and benefits, but out of simple inertia. A model of the consumer making active choices is inappropriate.

The obvious next question is: does it matter in practice? I have only limited time in which to answer that question, but research by Fair Pensions suggests that it does. For example, in its survey of the top 10 commercial pension providers, oversight of external managers’ investment governance appeared to be virtually non-existent. The new philosophy of judgment-led supervision includes being forward-looking in anticipating the risks that threaten market integrity. The solution to the governance gaps among those with the discretion to manage other people’s money does not lie in prescribing even more boxes to tick. The Bill should create a framework in which consumers can have trust. The basic principle is simple. If you are looking after someone else’s money, whether as an asset manager, an insurance company, a trustee, a consultant or any other licensed agent, the starting point should be that you must act in that person’s best interests. It is changed behaviour that we need, not simply compliance.

Finally, this Bill is not an easy read because it contains many amendments to the Financial Services and Markets Act 2000, although not to Section 348, which restricts the publication of confidential information by regulators. Consumer groups are concerned about this section. The Joint Committee shared this concern. It recommended that:

“Neither Regulator should be unnecessarily restricted from disclosing information. Section 348 should be amended to make it as unrestrictive as is possible within the confines of EU law”.

The Treasury review commissioned by the Financial Secretary found that even with Section 348 in place, the regulator could be far more open, and as a result the FSA has committed to a fundamental review of transparency. A letter from the Financial Secretary to the right honourable Peter Lilley on 21 May 2012 states that,

“the Government and FSA senior management are absolutely committed to embedding transparency and disclosure as a regulatory tool”.

I ask the Minister to confirm that the Government will amend legislation accordingly should the FSA conclude that that is required to achieve the commitment that the Government have made.

Queen’s Speech

Baroness Drake Excerpts

Wednesday 16th May 2012 Lords Chamber

[Baroness Drake]

My Lords, the focus in the Government’s programme on fair markets and the regulation of the financial services sector is to be welcomed. With auto-enrolment into pensions, millions more people will save through capital markets. Confidence in those markets has been worn down by mistrust, scandals, charges, complexities and conflicts of interest. Fiduciary duties exist to ensure that intermediaries—those who exercise discretion over other people’s money—act in the best interests of those whose money they look after. However, interpretations of this vital legal principle are dysfunctional, which undermines outcomes for savers, holds back effective shareholder oversight and allows conflicts of interest to prevail.

Those saving in trust-based occupational pensions should be protected by trustees who are legally obliged to act in their best interests. Those saving with an insurance company are subject to the consumer responsibility principle. As FairPensions points out, most savers are unaware of this legal divide. With auto-enrolment, the employer chooses the pension provider and the power of inertia increases saving. The inadequacy of the caveat emptor principle in that situation is evident. However, depending on the type of scheme their employer chooses, savers will find themselves subject to one of two opposing principles: fiduciary duty or caveat emptor. The law should be clarified to overcome the misperception that investors’ duties begin and end with maximising quarterly returns. The Government must provide better understanding and enforcement of investors’ true fiduciary duties.

The Work and Pensions Select Committee concluded in its recent report on auto-enrolment that,

“the Financial Services Bill … offers the opportunity for the Financial Conduct Authority … to look at approaches such as that of introducing something akin to a fiduciary duty for those running contract-based schemes”.

The Joint Committee on the draft Bill recommended that the Bill,

“place a clear responsibility on firms to act honestly, fairly and professionally in the best interests of their customers”.

The Government have responded with a new principle that firms must,

“provide consumers with a level of care that is appropriate”.

I fear that that will prove inadequate.

The issue of rewards for failure is the litmus test of how well fiduciary investors are protecting these savers’ interest in well governed companies delivering sustainable returns. As Professor Kay observed in the interim report of his review of UK equity markets, the purpose of equity markets is to improve the performance of companies that are ultimately the only thing that generates value for savers. They drive growth and create jobs. There is a fundamental alignment between the success of companies and the returns to savers. Equity markets exist to serve companies and savers, not to enrich intermediaries.

By this standard, the pensions industry is weak. From 2000-07, real returns to savers averaged just 1.1% per year, and pension fund payments to intermediaries rose by an estimated 50%. Fiduciary standards of care are an essential part of building a financial system that serves savers and the economy. I agree that it was surprising that the Queen’s Speech made no direct mention of executive pay and shareholder rights. Mean FTSE 100 executive pay rose by 49% from 2010-11. Austerity has clearly passed them by.

The shareholders’ spring has seen the flexing of voting power on remuneration reports, but this will not be sustained without addressing the conflicts of interest and behaviours of institutional investors responsible for casting votes on behalf of funds, many holding the savings of millions of people. Take, for example, regulation of the 25 million with-profits policies worth £330 billion. There is no explicit fiduciary duty to protect the best interest of policyholders. Consumer groups such as Which? have criticised the regulatory framework for with-profits policies and failure to control conflicts of interest. The Prudential Regulation Authority will assume responsibility for systemically important insurance companies, but it will not have the remit to protect proactively consumers who hold with-profits policies.

The Bill must provide for the PRA to consult the FCA and consumer groups on the consumer interest. The Government want transparent regulators, but consumer groups and the Joint Committee on the Bill expressed concerns that Section 348 of the Financial Services and Markets Act gold-plates single market directive limitations on the use of confidential information and will prevent the FCA from using the new powers that the Bill gives to it. The Financial Secretary to the Treasury, Mark Hoban, has confirmed that the Treasury will undertake a review of Section 348 with its recommendations made available through the passage of the Bill. I dearly hope that those recommendations will support disclosure.

Finally, figures from the Community Development Foundation show that about 4% of lending to SMEs goes into businesses in the most deprived communities. I recently read an article about the payday loans company Wonga.com launching a service for small firms. Its founder, Mr Damelin, is quoted as saying:

“All our research … tells us that small-business lending is broken and we intend to use our platform to offer a real alternative”.

Banks are failing to extend credit to small companies, but this reveals a worrying development in the credit market that exposes small firms, particularly small firms in deprived areas, to exponentially high rates.

The culture of the financial services industry must change and it must behave, in the words of the business Secretary, Vince Cable, as the servant of the economy, not its master.

Savings Accounts and Health in Pregnancy Grant Bill

Baroness Drake Excerpts

Tuesday 7th December 2010 Lords Chamber

[Baroness Drake]

My Lords, fairness dictates that the savings gateway and the children’s trust fund are worthy of greater consideration than straightforward abolition. Issues of affordability could be addressed by greater targeting and deferment. Policies focused on improving benefits and policies directed at asset-building for lower-income groups should not be seen as alternatives. It is not a matter of choosing either/or but of recognising that addressing inequality is a complex challenge.

I always fear what I call the “rational” paternalism that argues that those on lower incomes should not aspire to save and accumulate assets, should not expect government policies that allow them to do so, should have to accept that the market will not cater for them and must forgo the greater control which assets can bring over household debt. Meanwhile, the systemic inequalities in asset distribution simply get worse. I wonder how rigorous the impact assessment of this Bill has been, because while income inequality attracts greater attention, assets are far more unevenly distributed. Financial inclusion policy persistently fails to take adequate account of asset fund-building policies, despite the fact that assets directly affect financial inclusion.

As has been said, more than 60 per cent of black and Asian people in the UK have no savings at all. Women have 40 per cent less than men. Lack of assets is a problem for people who run into financial difficulties—lack of control takes over. Poor people who lack rainy-day savings are exposed to subprime and even illegal lending practices. Savings provide an alternative to high-cost credit and have the potential to change the long-term flow of money within a family. Those without savings are exposed to high charges for other products, such as insurance. Owning assets has an impact on confidence, sense of control and willingness to engage.

There is a difference between recognising the public spending challenge, and so moving to targeting, and deconstructing the complete edifice, which is what the Bill does. The child trust fund gave a real kick-start to the savings accounts of children of people on lower incomes. It overcame inertia, combining auto-enrolment with a strong and simple incentive. It made the provision of such a savings product for lower-income families more attractive to the financial markets. It allowed providers to do some cross-subsidy between their richer and poorer clients. It increased accessibility to a savings product for low-income groups. The product was taken to them; they did not have to search the market. The momentum that has built up in this product—75 per cent take-up is pretty high, compared with a lot of products—could have been sustained over the longer term.

Particularly regrettable, as so many noble Lords have said, is the abolition of the trust fund for children in care—some of the most vulnerable and least well placed in terms of assets. Who will look after the asset accumulation of our vulnerable children in care now? In response to the noble Lord, Lord Newby, is it so wrong for children in care to get a windfall asset? They certainly will not get the windfall asset of a tax-free inheritance, up to about £325,000. I ask the Minister to seek from the Government a commitment to continue such payments and, if the vehicle is a junior ISA, to require payments to be made into that account. An annual payment of the order of, for example, £100 would be small in the scheme of things, but it would make a real difference to those individual children.

I also ask the Minister whether the Government will commit to addressing this issue in another piece of legislation if it is not possible to amend the Bill. I refer to the comment of the Prime Minister at Question Time on 30 June 2010, when he said:

“We really do need to do better as a country”,

for care leavers. He went on to say that,

“children leaving care aged 18 have … no one to help them”.—[Official Report, Commons, 30/6/10; col. 857.]

Here is a chance for the Government to help those children in care and to meet the aspiration that the Prime Minister himself articulated.

Child trust funds for disabled children worked alongside the benefits system. Although the Government have said that they will redirect some of the abolished payments for short-break provision, does such provision and asset-building for disabled children truly have to be mutually exclusive? Is it not possible for the brains of the Treasury to find a more worthy set of candidates who could bear the marginal contribution to the public debt of making those modest payments to disabled children? Could the Minister not give an assurance that they will consider maintaining even a modest payment for those children and, when more benign economic circumstances allow, making those payments more generous?

What about the impact on ethnic minority children? The BME age profile is much younger than the national average. Proportionately more of them would be able to receive a trust fund. That is important because the low level of assets held by black and minority ethnic parents means that they will be less able to benefit from familial redistribution.

Notwithstanding what has been said, I fear that the Government are dismantling the child trust fund and replacing it with a savings vehicle which will widen inequality and undermine the behavioural momentum that was being built up for low-income groups. Junior ISAs will provide tax-free returns, but there is a public cost to extending that tax-free element. It is revenue forgone, and it is affluent parents who will secure the greatest benefit on behalf of their children. It is much less likely that junior ISAs will be as effective in increasing the level of new savings. If that is the concern, then these junior ISAs will probably deliver less, because many low and moderate earners simply will not engage with such mainstream products. The trust fund worked because the product was taken to them. It took away the inhibitions and the complexities of engagement that many financial products involved.

Let us again consider BME people. Not only do they have lower amounts of savings; they utilise mainstream financial products even less, in particular ISAs. If junior ISAs are to substitute for the child trust fund, do the Government intend to consider this deficit of engagement with mainstream financial products particularly among low-income and BME families?

There is another important difference. An ISA is run on an annual renewal basis, whereas a child trust fund is run as a trust over a much longer period. This is an important distinction. The financial services industry often takes advantage of inertia. Customers are frequently defaulted into ISA products with extremely low interest rates, and even interest rates on fixed-term cash ISAs are frequently below the returns available on non-tax-exempt products, thereby undermining the public policy intention of introducing the ISAs in the first place. If the Government are to introduce ISAs for children, will they take action in designing them to hold the markets to account for the practices I have described? ISAs are not trusts.

Statistics reveal that lower-income families’ contributions to their children’s trust funds formed a greater percentage of their income: 1.14 per cent, compared with 0.76 per cent for more wealthy families. Who says that poor people do not want to care for their children? Those who do contribute give up, on average, a higher percentage of their family income. Families earning £16,000 or less have on average been saving £15 a month into the funds. That momentum might well have been maintained but now we will never know. If we are to help poor people to build assets, we are going to have to start again with that momentum and engagement. Seventy-five per cent was a jolly good start compared with some products. I wish that one could get that level of engagement in free contributions from employers to occupational pension schemes. It would be so much better if the Government targeted even a modest amount of money on the most disadvantaged children.

Similarly with the abolition of the saving gateway, the effect of the Bill means that although we will have a relatively generous pension and inheritance tax system, the two incentivised savings products for low-income households and their children will be scrapped. The issue of affordability will not be addressed by targeting. Providing low-cost products for low-income savers will always be a challenge for the financial services industry. Put at its simplest, such products do not provide an attractive profit. That is precisely why government support for initiatives such as the savings gateway is so important for meeting a market gap. By withdrawing so absolutely from the savings gateway, the Government have simply heightened the political risk for financial services organisations of investing in savings products for lower-income groups. Who is going to do that now? When people have built up such savings, they have been downed and no one knows what the future might hold.

The Government admit to the possibility of returning to the issue because they know, as everyone else does, that interfacing with the financial services industry is a persistent problem for low-income people. Why cannot the savings gateway be deferred, or its introduction phased in, so that the positive gains from the project can be banked, so that those parts of the financial services industry that have engaged can remain engaged and so that the cost could be minimised in the short term and highly targeted in the long term? Why scrap? You could make a huge contribution to the issue of affordability without downing the edifice and abolishing in the way proposed.

I recognise that a financial advice service is to be rolled out and that that is a real positive. Citizens have a right to enjoy financial advice and to be given guidance on how to exercise their financial interests and responsibilities. However, there are reams and reams and books of evidence to show that advice often does not lead to active decisions to save, particularly among low-to-moderate earners. The DWP has trialled schemes with employers but advice has not translated into action, which is why nudging, powerfully incentivised and well designed default products are so important to increasing saving. Instead of targeting and keeping the remnants—keeping some of that edifice alive—all the work is being abolished.

Finally, financial education for children is likely to have much more impact if all children, the poor as well as the affluent, have a sum of money in an account with their name on it. That would have much more meaning.

Equitable Life (Payments) Bill

Baroness Drake Excerpts

Wednesday 24th November 2010 Lords Chamber

[Baroness Drake]

My Lords, I should declare that I am a trustee of pension schemes with some members who have AVC savings in Equitable Life.

One has to enter the discussion on this Bill by acknowledging the extent of the anxiety and hardship that all too many Equitable Life policyholders have experienced. I recognise that the Bill is an important step in resolving the Equitable Life affair, which is to be welcomed. However, as has been said, the Bill gives the Treasury power to make payments without the full detail of the compensation scheme currently having been published. This raises some matters of concern on which I seek clarification.

The Government have confirmed a definition for relative loss suffered by policyholders, an approach that encompasses all the Parliamentary Ombudsman’s findings of maladministration, which the Government fully accept. I note that that decision by the Government leads to the taxpayer carrying liability for a form of compensation, which may well set for the future a moral precedent, expectation, or indicative principles of some significance. It would be useful if the Minister could clarify the point made by the noble Lord, Lord Kirkwood, about whether these payments are in fact ex gratia in status. I had understood that they were not. The actual amount of public funding for the compensation payment scheme is to be constrained by considerations of the public purse, in line with the view of the ombudsman. Such a consideration would always be relevant, whatever the state of the economy at a particular time. The state of the public finances may influence the weight that is given to this consideration, but not the principle of consideration itself.

The Government have determined that the total funding for the Equitable Life payment results in a figure of £1.4 billion and a £0.1 billion contingency for longevity risk. The distribution of that aggregate figure in allocated payments has been determined in part by the Government with £620 million to cover the total relative loss suffered by with-profits annuitants, £775 million to be distributed between approximately 500,000 holders of individual policies, and £600,000 in GPPs. As to further distribution to these latter policyholders, the independent commission set up by the Government is looking to determine and apply a set of principles for the fair allocation of funds. Those principles will also underpin any prioritisation of payments.

Therefore, two key sets of judgments or decisions are being made here that are important not least for the expectation principles that they may state morally, if not legally, for the future: what adjustments to make to the £4.3 billion relative loss figure for public purse considerations; and what principles of fairness to apply to the allocation of funding and the priority of payments to policyholders who are not with-profits annuitants.

If we take the first matter, it is not clear, as my noble and learned friend Lord Davidson said, how the relative loss figure has been abated for public purse considerations. What were the considerations that led to that £1.5 billion figure being announced in the spending review? How have the Government decided to ameliorate their liability? Little or no adjustment has been made to the compensation for with-profits annuitants as the Government propose to cover their total relative loss because of the irreversible nature of the purchase transaction and the size of the losses. It is the funding allocated to the other categories of policyholders where the extent of the adjustment to the public purse is greatest and the reasoning least transparent. These issues are very important. How matters were determined in this instance could well influence the reasoning of others when borrowing in future. It is important to understand whether the process followed by the Government is based on safe and sound principles. I noted that the Parliamentary Ombudsman said in the Public Administration Select Committee on 14 October:

“My view was that compensation for relative loss was the appropriate remedy. Then I did something unusual, which is to say, ‘That's a very large sum of money, and I absolutely understand that considerations of the public purse can legitimately come into play’”,

thereby confirming her statement that we are in new territory.

As to the second matter, principles of fairness identified by the independent commission may also set an expectation. Will the Government reflect on this before accepting any recommendation, not least to ensure that there are no untenable contradictions as to the hierarchy of priority between this compensation scheme and others that may exist, including pension saving compensation schemes? Hierarchies of priority have proved contentious in the past, not least in respect of pension savings.

Clause 1(3) confers on the Treasury the power to make provision for the payments to be disregarded for the purposes of tax, entitlements to tax credits and the liability to make payment in respect of provision for goods and services. On 10 November, the Financial Secretary to the Treasury, in his response to a question in Committee, confirmed that payments should not be treated as income for tax purposes, so providing a benefit for policyholders. If that is the case, will the Minister say whether the loss to the with-profits annuitants is calculated on a gross basis, whether the reference to disregarding payments for the purposes of tax credits would be extended to entitlements to pension credits and savings credits, and whether any payments can be disregarded in respect of liability or payment for social care?

I have also been reflecting on non with-profits annuitants. Is there an issue to be addressed in distinguishing between the holders of indexed and level annuities when assessing relative loss?

I recognise that the Government are keen to start making payments as soon as possible. Speed is obviously important, particularly given the age of many with-profits annuitants. The independent commission is looking at whether the timing of any payments could be prioritised, but will the Government also consider making interim payments soonest to those who need them most? Notwithstanding the aspiration around the timetable, does the Minister remain confident that the report from the independent commission will be received by the end of January 2011 and that payments will commence by the end of the first half of 2011? It would also be welcome if the Minister could confirm that a review body will definitely be accessible to policyholders who wish to challenge payments, with the review body having the power to overturn calculations.

I recognise that the Government’s weighing of the public purse with the compensation for injustice is a difficult issue. Citizens look to the Government to protect them against injustices experienced as a result of regulatory maladministration or inadequacy. Equally, the Government have a duty to taxpayers to have regard for the liability and responsibilities which they require the taxpayer to accept and the competing demand for public resources—a difficult balance. There have been significant controversial compensation cases over the past few years, as instanced both by Equitable Life and by the creation of the financial assistance scheme that was set up to compensate pension scheme members whose employers became insolvent prior to April 2004. It is probably appropriate for me to say that I am on the Pension Protection Fund board, which of course administers the financial assistance scheme.

It is important that people are not put off saving, and off pension saving in particular. I share the concerns of the noble Lord, Lord Kirkwood, who said that we must avoid such a tragedy happening again. How confident are the Government that their approach to regulation will ensure that such a tragedy does not happen in the future? With the advent of auto-enrolment in 2012, we will see millions more people saving and a significant increase in the level of saving going into private pension provision. Much of that saving will go into contract-based pension products. We will also see a corresponding growth in the annuity market. It is important that the regulatory system for long-term saving is robust and fit for purpose. There is a need to create an environment in which the need for compensation in the future becomes negligible.

The policy of auto-enrolment strikes a deal between the Government and the citizen that the latter will take greater responsibility for saving for their retirement. In return, the citizen deserves a regulatory system and a standard of governance and behaviour in the financial and insurance industry that support them in taking on this responsibility. I know that the Government are set on a programme of reform for financial regulation and the creation of a new consumer protection and markets authority.

The noble Lord, Lord Kirkwood, referred to conflicts between regulators. There are currently two regulatory regimes in the area of pension saving—the Pensions Regulator and the body or arrangements that will replace the Financial Services Authority. I will not go into the detail of who covers what, but there is an issue to be looked at here because there is unquestionably regulatory overlap, particularly as the future will provide a combination of contract-based and trust-based saving.

In implementing these reforms, will the Minister give the assurance that giving savers confidence in insurance and long-term saving in the future will be at the forefront of government policy and action?