Financial Services and Markets Bill [HL] Debate

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Department: HM Treasury
Lord Altrincham Portrait Lord Altrincham (Con)
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My Lords, notwithstanding the anomalies that have been discussed—there are significant anomalies in insurance in England as well—we have some concerns about this amendment. It would hand the Treasury very extensive powers to act through secondary legislation, including the ability to amend primary legislation. We have raised concerns consistently in Committee and on Report about the use of broad, delegated powers of this kind. The same concerns apply here. Regulations being subject to the affirmative procedure provides a degree of parliamentary scrutiny. However, it does not alter the fundamental point that Parliament will be delegating significant legislative discretion to the Treasury before the detailed regime on any transitional arrangements has been set out.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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My Lords, Amendment 16 would give the Treasury the power to extend regulation of claims management activity to Northern Ireland through secondary legislation. I am aware of the concerns relating to high insurance costs across the UK and would be supportive of action to tackle these where we can, but we should not rush to regulate without clear evidence.

The Government’s Motor Insurance Taskforce has examined the drivers of motor insurance costs, including claims-related costs and market practices. This work has not identified clear evidence that claims management companies are a primary driver of higher premiums in Northern Ireland. Moreover, any proposal in this area would also need careful engagement with the Department of Finance in Northern Ireland and proper consideration of the devolution implications. I therefore ask the noble Baroness to withdraw Amendment 16.

Baroness Hoey Portrait Baroness Hoey (Non-Afl)
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My Lords, there I was thinking that we had a Minister who was going to be much more reassuring, but, in fact, that was a very negative response. All the things he said have already happened and could be happening in more detail if the Government were to move forward with this. It really is a missed opportunity for the Government and it is not going to go away; it will have to come back in a different form.

I had not realised until recently—probably like many people here tonight—how appalling this situation is. I do not know where the Minister got his facts and figures; perhaps from the Treasury, but certainly not from the people who know what is going on in Northern Ireland. There is obviously no point putting this to a vote tonight, but I hope that, following this, the Minister will meet a group of us who understand this a bit more and will make it clear to him that perhaps, sometimes, he might be given the wrong advice. I beg leave to withdraw my amendment.

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Baroness Neville-Rolfe Portrait Baroness Neville-Rolfe (Con)
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My Lords, we are concerned about the scale of fraud, and in particular by the continued growth of authorised push payment fraud and other forms of online economic crime. The Government and the banks have made progress, but the truth is that it is hard to keep up with the scammers, and the sums at stake are significant, as the noble Baroness, Lady Kramer, has explained. I therefore strongly welcome the proposal from the noble Lord, Lord Vaux, for an annual report.

My noble friend Lord Howard of Rising is right to be concerned about the future protection of commercially sensitive information as part of a competitive UK sector. I am glad he has brought his amendment back, and I hope the Minister will be able to provide an assurance that this will be addressed.

The amendments in this group raise important questions about transparency, monitoring and the practical steps that firms can take to identify scams earlier, warn consumers, share information more effectively and pay compensation where that is appropriate. Indeed, there has been considerable progress since the APP reimbursement regime was introduced in 2024. I always remember my card being used in Korea to buy £2,500 worth of Louis Vuitton luggage. That would not happen today, as banking procedures and scrutiny are so much better.

However, the proposal from the noble Baroness, Lady Kramer, is a difficult one, as it is not clear what the technology companies could do to stop fraud systematically. They are not passing money on in the same way as the banks do. That may have been what the noble Lord, Lord Stockwood, was getting at in Committee when he responded to this amendment at that stage. New regulations of this kind could also have a chilling effect on the supply of online services in the UK, so more analysis is needed before the FCA introduces new rules. We believe this is an area where the Government and the regulators should be prepared to make progress, but we also understand the constraints.

It is also important that people learn to avoid scams with simple procedures such as face ID, and to take care over what they buy online. This should be an important part of education, and indeed Ofcom, working with the FCA and the tech companies, should be able to make more progress here. I very much look forward to the Minister’s response on this important area and how he thinks we can best address this problem.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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My Lords, before I respond, I must start with a correction. In the third debate, I said that commercial credit data-sharing schemes improve bank referrals and strengthen personal lending. However, the CCDS and the bank referral scheme are different schemes. To correct the record, I meant that the Government are improving competition and supply through enhancements to commercial credit data sharing in this Bill and working with industry to strengthen bank referral arrangements. Both these schemes help to improve lending to SMEs. I apologise for that; I was speed-reading my way through my responses. I will try to be more careful in future.

I am grateful to the noble Baronesses and noble Lords for tabling these amendments and to all noble Lords who have contributed to this debate. On Amendment 17, fraud causes profound financial and emotional harm. As noble Lords know, this Government take the issue of fraud very seriously and are dedicated to protecting UK citizens. As my noble friend Lord Stockwood explained in Committee, the Online Safety Act requires tech companies to take proactive steps to prevent fraudulent content. The Government remain committed to ensuring that Ofcom makes full use of its powers to undertake fast and decisive action against illegal online harms, including fraud. At the request of the Secretary of State, Ofcom will share an annual update on its enforcement strategy for online safety with Parliament.

In July, Ofcom published the fraudulent advertising code consultation, proposing more than 40 new measures to tackle online fraud on the UK’s biggest digital services. Among these measures, Ofcom proposes the mandatory verification of financial services advertisers. This will support legitimate financial promotions from FCA-authorised firms while cracking down on illegal financial promotions such as scam investments and crypto ads.

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Lord Vaux of Harrowden Portrait Lord Vaux of Harrowden (CB)
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I am terribly sorry to interrupt the Minister, but perhaps he could explain why the FCA has stopped the reports that the PSR was previously providing.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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I am unable to answer the noble Lord’s question; might I write to him with an answer?

Amendment 20 was discussed in Committee and the Government’s position remains unchanged. As set out in Committee, a range of measures is already in place and further work is under way across government, regulators and industry. This includes firms using increasingly sophisticated fraud detection systems, confirmation of payee checks, work to improve data sharing between payment service providers and steps to ensure that fraud prevention is built into the design of future retail payments infrastructure.

Turning now to Amendment 95, concerning the protection of intellectual property, I agree that weak protections can be a drag on competitiveness. On non-compete clauses, in particular, there are no provisions in the Employment Rights Act 2025 that would affect the use of non-compete clauses by financial services firms. The Government published a working paper on options for reform of non-compete clauses in employment contracts at Budget 2025. We are currently reviewing responses and will respond to the working paper in due course. The focus of the paper was on options for reform of non-compete clauses in employment contracts. It does not consider reform to intellectual property law or other means to protect confidential information. The Government understand that a well-designed, balanced intellectual property system offers confidence for business investors and consumers to contribute to growing our economy.

Turning finally to Amendment 97 in the name of the noble Baroness, Lady Bennett, I recognise the continued threat posed to the UK by ransomware criminals. Following public consultation last year, this Government are already taking forward work through the Home Office to break the business model of ransomware and provide law enforcement with the information it needs to understand, investigate and disrupt ransomware activity. This includes proposals for a targeted ban on ransomware payments and mandatory reporting for businesses above a certain size. Taken together, the Government consider that the objectives of these amendments are already addressed through the existing framework and work that is under way and do not believe that further statutory requirements are needed. With that in mind, I ask noble Lords not to press their amendments.

Baroness Bennett of Manor Castle Portrait Baroness Bennett of Manor Castle (GP)
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Before the Minister sits down, can I ask for a potential timeframe on when the noble Lord expects to see progress on that work in the Home Office?

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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Again, if the noble Baroness will accept it, I will write to her on that. I do not know the timetable offhand.

Baroness Kramer Portrait Baroness Kramer (LD)
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My Lords, the online platforms know exactly what they have to do to stop online fraud; they are just choosing not to do it. The Government say that the answer will come from Ofcom, but that has certainly not worried the platforms one iota. The platforms will take notice only when they have to pay out to reimburse people who have been victims of those fraud scams. That is why Amendment 17 matters, and that is why I am going to test the opinion of the House.

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Moved by
18: Schedule 2, page 78, leave out lines 27 to 30
Member’s explanatory statement
This amendment would remove a subsection which duplicates section 131Z19 of the Financial Services and Markets Act 2000 (inserted by paragraph 18 of Schedule 2).
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Moved by
21: Schedule 2, page 83, line 5, leave out “131Z12, 131Z13 or 131Z14” and insert “131Z13, 131Z14 or 131Z15”
Member’s explanatory statement
This amendment would correct a cross-reference.
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Moved by
22: Schedule 2, page 85, line 13, at end insert “, and
(ii) in its application as a secondary objective, the objective set out in section 30J(1) of the Bank of England Act 1998 (payment systems etc: innovation).”Member’s explanatory statement
This amendment is consequential on the amendment in the name of Lord Pitt-Watson that inserts a new clause after clause 22 relating to the Bank of England’s functions relating to payment systems and service providers.
Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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In moving my Amendment 22, I will also speak to government Amendments 58 and 59. Amendment 22 is developed from our discussions in Committee.

Payment systems are essential national infrastructure. They allow households to pay bills, businesses to trade and financial institutions to transfer funds securely. As technology changes how we pay, those systems must continue to evolve, becoming more efficient and capable of supporting new services while remaining trusted and resilient. The Bank of England has a critical responsibility to protect and enhance UK financial stability. The Bank is also working with the Government and other authorities to support safe innovation in payments and digital finance. The Bank has welcomed this measure and will reinforce that work while preserving the primacy of financial stability.

Amendment 58 places the Bank’s role in facilitating innovation on a clear statutory footing. When exercising certain key functions for recognised payment systems, recognised digital settlement asset service providers, and in-scope service providers, the Bank must, so far as is reasonably possible, facilitate innovation with a view to improving the quality, functionality and economy of those systems and related services. The objective is expressly secondary and does not require the Bank to facilitate innovation where doing so would undermine its primary financial stability objective. This change will also bring the regulation of systemic payment systems and digital settlement assets into closer alignment with the Bank’s supervision of other financial market infrastructure. The Bank already has a secondary innovation objective for central counterparties and central securities depositories. Providing a comparable objective for payment systems and digital settlement assets provides the Bank with a clear and consistent statutory framework.

Amendment 58 also ensures that the Bank can be held accountable under its new objective. It enables the Treasury to make recommendations about aspects of the Government’s economic policy for the Bank to have regard to when considering how to advance its financial stability and secondary innovation objective in relation to payment systems. Those recommendations must be published and laid before Parliament. The Bank must explain the action it has taken, or its reasons for not acting, and provide updates where required. The Bank’s annual reports must now also explain how it has advanced the secondary innovation objective and engaged with interested stakeholders.

Amendment 59 reinforces that accountability by requiring the Bank to publish a stand-alone annual report on both secondary innovation objectives. The report must explain how objectives have been embedded in the Bank’s operations, processes and decisions, and how it has advanced them with respect to relevant functions. This will give Parliament and industry clear sight of how the objectives operate in practice.

Amendment 22 is consequential. It ensures that the mechanism already in the Bill for co-ordination between the Financial Conduct Authority, the Prudential Regulation Authority and the Bank with respect to relevant payment functions makes appropriate reference to regulator objectives, which would now include the Bank’s secondary innovation objective.

In summary, these amendments together place the Bank’s role in facilitating safe innovation on a clear statutory footing, while preserving financial stability as its primary objective. They also provide stronger and more transparent accountability for how the Bank applies the objectives in practice. I hope that noble Lords will join me in supporting these amendments.

Baroness Kramer Portrait Baroness Kramer (LD)
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My Lords, I have a couple of very brief comments. I am comfortable with the amendments that the Minister has just described, but I have one note of caution. The drive for innovation, which we all think is a good thing, in many ways also increasingly exposes the UK to a loss of monetary sovereignty, particularly where that innovation has to be brought in from overseas, and gives overseas companies far greater control of the payments systems in the UK. That is one of the ongoing fears that we have had. Scott Bessent has been quite open in saying tariffs are very old-fashioned in controlling western economies’ and that stablecoin is the way to do it.

I am therefore cautious when I hear this drive for innovation without some counter-warning and counter-consideration of the monetary sovereignty impacts. I never hear those words used, nor are they captured in any way in anything that I hear around regulation. So often, the move into digital assets—which is, in essence, what this is all about—is about plumbing and pipelines; it does not recognise the political implications. We have seen this in many other areas, such as where we have given away food security and energy security. We need to be very careful that we do not give away security in the financial services and payments sector.

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Moved by
23: Schedule 2, page 93, line 6, at end insert—
“(aa) in paragraph 2(3), omit“, (ca)”;”Member’s explanatory statement
This amendment would remove a cross-reference to the paragraph omitted by paragraph 58(a) of Schedule 2.
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Lord Altrincham Portrait Lord Altrincham (Con)
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My Lords, these amendments reflect a number of important concerns about the proposed transfer of anti-money laundering supervision to the FCA. We do not believe that each of these points requires legislative commitment. However, we have also been made aware of serious concerns from industry about how this transition is being communicated and how the new regime will work in practice.

These concerns include the governance arrangements following the transfer of the timetable and the transitional process, the maintenance of professional standards, proportionality, and the extent to which the FCA will retain specialist expertise needed to supervise highly technical sectors such as accountancy, legal services and trust and company service provision. There are also legitimate questions about the practical support available to firms, the likely cost of the new regime and whether smaller firms in particular will face disproportionate burdens.

This is why our Amendment 93, in my name and that of my noble friend Lady Neville-Rolfe, covers a transfer of AML supervision. Parliamentary and entire industry oversight of these changes will be vital in making sure that this new architecture works in the way the Minister wants.

The common thread running through our amendment and the other amendments in this group is therefore a sensible one. If the Government are going to centralise this responsibility within the FCA, they must demonstrate that the FCA is genuinely equipped to undertake it, and provide clarity to industry about how this process is going to be practically achieved. That means not simply having the formal regulatory powers, but having the right people, the right sectoral knowledge, appropriate transitional arrangements and a clear understanding of how supervision will operate across the country.

Industry is concerned about these questions, and those concerns should be taken seriously. I therefore hope the Minister can make a firm commitment today to provide considerably greater clarity about how this transfer will be implemented, how professional expertise, standards and proportionality will be maintained, and what firms should expect during transition.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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My Lords, I am grateful to the noble Baroness, Lady Kramer, for tabling these amendments concerning the implementation of the reform of the UK’s anti-money laundering and counterterrorist financing supervisory regime. The points everyone is raising about the implementation of this needing to be well done are extremely important, as is the comment made by the noble Lord, Lord Altrincham, about parliamentary oversight of what is taking place here.

Amendments 26 and 27 concern support for firms and implementation planning. Amendment 26 would require the Treasury to publish and lay an assessment before Parliament, including a comparison between the education, guidance and compliance assistance currently available to firms and the support that will be provided by the FCA. The Government recognise the concern that professional services firms should continue to receive clear guidance, appropriate support and access to sector-specific expertise following the transition to the FCA.

Existing provisions in the money laundering regulations, which require supervisors to provide information about money laundering risks to supervised populations, will apply to the FCA in relation to its expanded responsibilities. The FCA already has significant experience of providing AML/CTF information and guidance to a large and diverse supervised population. For these reasons, the Government do not believe that a statutory assessment is necessary.

Amendment 27 would require the Treasury to publish a statutory timetable for implementation. While we do not believe such a requirement is necessary, the FCA has provided some additional clarity on the expected implementation timetables. The current expectation is that the first businesses will begin to be supervised by the FCA before the end of 2028. Further onboarding will take place in phases, with the broad aim that all firms within scope will be supervised by the FCA by mid-2030.

Implementation should proceed only when the necessary preparations are complete. This includes ensuring that appropriate systems and effective information-sharing arrangements are in place, supervisory staff are adequately trained, and sufficient clarity is provided to firms about the future regime. Retaining flexibility will allow the Government and the FCA to respond to stakeholder feedback and lessons arising during the transition.

Existing supervisors will continue to supervise firms, taking enforcement action where necessary and maintaining standards until the FCA assumes its new responsibility. The Office for Professional Body Anti-Money Laundering Supervision, OPBAS, will continue to oversee the existing professional body supervisors during that period. The FCA is already engaging with professional body supervisors and HMRC on information-sharing and data-sharing arrangements.

Amendment 28 concerns professional expertise. The Government fully recognise that effective supervision depends on supervisors understanding the sectors they regulate. Legal services providers, accountancy firms and trust and company service providers have different business models, risks and regulatory arrangements.

Of course, the FCA already supervises a large and diverse population, including many smaller firms, and has extensive experience applying a proportionate, risk-based approach across different business models and firm sizes. The FCA’s independent Smaller Business Practitioner Panel also provides direct insight into the perspectives and challenges facing smaller regulated firms.

This reform is not about applying a banking-style or one-size-fits-all supervisory model to professional services firms. The future regime will be proportionate and risk-based and establish a more consistent and effective framework, while recognising the different characteristics and risks of those sectors.

Amendment 29 is on supervisory fees. All businesses, particularly smaller firms and sole traders, want assurance that the future regime will remain proportionate and that firms will not be required to pay excessive supervisory fees. The FCA will consult on the design of its future fee model before assuming responsibility for these sectors. The Government expect fees to be proportionate and consistent with the FCA’s wider fee framework, where smaller firms generally face lower costs than larger firms. The detailed fee structure will depend on the final supervisory model and is therefore better developed through consultation.

Finally, Amendment 30—

Lord Russell of Liverpool Portrait Lord Russell of Liverpool (CB)
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My Lords, I apologise for interrupting. The Minister has not answered the question of what assessment the Government have made of the cost impact on firms of moving from a single supervisor to dealing with two, particularly for small firms.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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I am not aware of an individual calculation that has been done for that. I do not think that there will be a materially greater cost once the move is made. The key issue that we are trying to address here is that, right now, we have 23 regulators of AML, and that job needs to be done in a more co-ordinated and consistent fashion. If I have information on that, I would be delighted to write to the noble Lord on those costs.

Finally, Amendment 30 addresses the FCA’s capacity to undertake effective AML/CTF supervision across all parts of the United Kingdom. Amendment 30 would require the FCA to report on its capacity to supervise firms throughout the UK. The FCA already operates across the United Kingdom through its offices in London, Leeds and Edinburgh and anticipates having a significant presence for the new AML regime outside London. This provides a strong foundation for maintaining regional coverage, preserving local knowledge and ensuring that jurisdiction-specific issues continue to inform supervision and implementation planning. This will also help with ensuring that regional risks and jurisdiction-specific considerations are understood and addressed, while maintaining a consistent approach across the United Kingdom.

I recognise the objectives behind these amendments: careful implementation, appropriate support, maintenance of expertise, proportionate fees and sufficient FCA capacity. The Government understand why these assurances are being sought. However, additional statutory reports, assessments and fixed requirements are not necessary. These matters are being addressed through implementation planning, capability building, stakeholder engagement, consultation and parliamentary scrutiny of the necessary secondary legislation. The Government will continue to work closely with Parliament, industry, existing supervisors and the FCA. Our aim is to deliver a more consistent, effective and co-ordinated AML/CTF supervisory framework, while ensuring that firms receive proportionate supervision and appropriate support. I therefore ask the noble Baroness, Lady Kramer, to withdraw her amendment.

Baroness Kramer Portrait Baroness Kramer (LD)
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I withdraw the amendment.

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Moved by
31: Clause 16, page 18, line 38, at end insert—
“(ba) the competitiveness and growth objective (see section 1EB), and”Member's explanatory statement
This amendment would clarify that the strategic priorities set out by the FCA in a long-term strategy under new section 1JZA of the Financial Services and Markets Act 2000 must include strategic priorities in relation to the competitiveness and growth objective.
Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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My Lords, growth is the top priority for the Government, and the financial services sector is key to delivering this. As my noble friend Lord Stockwood set out in Committee, the Government always intended that the FCA’s long-term strategy would set out its priorities for advancing its international competitiveness and growth objectives. The noble Baroness, Lady Noakes, rightly questioned if our legislative drafting was clear and, after further consideration, the Government have tabled this amendment to ensure that the law is clear on this point. I thank the noble Baroness for bringing this matter to our attention.

I turn to Amendments 32 and 33 which would place detailed statutory requirements on the content of the FCA’s and PRA’s long-term strategies, including requiring descriptions of future regulatory initiatives, indicative timelines and assessments of potential trade-offs. The Government agree that this is an important part of Parliament’s role in scrutinising the work of the regulators. I welcome the commitments made by Nikhil Rathi, the CEO of the FCA, in a letter he sent to me on 2 September, which has been shared with the Lords Financial Services Regulation Committee, the Opposition Front Bench and interested Peers. The letter made a commitment to pro-actively engage relevant parliamentary committees on their priorities before settling future strategies. Katharine Braddick, the new CEO of the PRA, also made commitments in her letter of 3 September to engage its stakeholders and Parliament in the development of its strategy. As I committed to earlier in today’s debate, I am placing these letters in the Library.

Much of the information that the noble Baroness seeks is, or should be, already available through existing channels, including the Regulatory Initiatives Grid, which is updated regularly and is specifically designed to provide firms and stakeholders with forward-looking information on forthcoming regulatory activity. The FCA also publishes and will continue to publish an annual work programme that details what it will deliver in the coming year against the strategic priorities in its current strategy.

The purpose of the long-term strategy is different. It is intended to set out the regulator’s strategic direction and priorities over a five-year period, rather than to operate as a detailed business plan. As the FCA sets out in its letter, the strategy is intended to provide greater clarity and predictability about its priorities, and to provide a strong basis on which Parliament and others can hold it to account for its performance against those priorities. The Government therefore do not consider that these additional statutory requirements are necessary.

I now turn to Amendment 68, which seeks to create new statutory offices for regulatory evaluation within the FCA and the Bank of England. I recognise the concerns expressed during Committee about ensuring that Parliament has access to meaningful information about the performance of the financial regulators. It is a point well made. This amendment would go further than this. It would establish permanent statutory bodies with dedicated directors, governance arrangements and reporting requirements, introducing additional costs on the regulators. As we discussed in Committee, there already exists a range of mechanisms to provide this information. This proposal could potentially duplicate these arrangements, and the Government do not agree that more institutional machinery will necessarily lead to better scrutiny.

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Baroness Neville-Rolfe Portrait Baroness Neville-Rolfe (Con)
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My Lords, I begin by paying tribute to my noble friend Lady Noakes, to the Financial Services Regulation Committee, including the noble Baroness, Lady Bowles, and the noble Lord, Lord Vaux, and to my noble friend Lord Bridges of Headley for their persistent pursuit of a very simple but important principle. As regulators gain more power and their remit expands, so too should the scope and effectiveness of the oversight to which they are subject.

My noble friend Lady Noakes powerfully articulated the concern that the FSMA model has been stretched too far and that even our expert parliamentary committees are struggling with the volume and complexity of oversight. We need stronger, not weaker, democratic accountability, which is why we saw value in the office of regulatory evaluation and/or my noble friend Lord Bridges’s original model tabled in Committee. We also share his concern about the dismantling of the Bank of England’s IEO.

This is an area where the Opposition will continue to develop our thinking for future legislation and would welcome engagement. We are not comfortable with a system whose reaction seems to be to delegate every new or persistent problem to our regulators. We are very pleased that my noble friend Lady Noakes will continue to work with the Treasury and the regulators on improving parliamentary oversight through the relevant committees, and we look forward to working with her and others across the House, including the noble Baroness, Lady Bowles. What she has proposed represents a practical compromise that would allow us to move on. However, a positive response to Amendment 93 on first use of the new powers would also be important.

One practical way in which the accountability gap could be narrowed a little—and, indeed, trust in the FCA improved—would be to strengthen the remit of the cost-benefit analysis panels, which already sit within the regulators. Their remit could extend beyond rule changes to include guidance and enforcement activity. They could be given the ability to request an assessment of changes that the regulator has judged to be immaterial. This would strengthen internal challenge, improve confidence in the regulatory process and provide Parliament with more useful and more independent information. I have not brought back yet another amendment on this proposal, but I hope the Minister can commit to looking seriously at it as a follow-up to this useful debate.

I welcome the Government’s amendment on competitiveness and growth. I am only sorry that the name of the Financial Services Regulation Committee does not seem to have made its way into the statute.

Lord Pitt-Watson Portrait Lord Pitt-Watson (Lab)
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My Lords, I will not take up too much time because I responded to many of the points at the beginning of the debate. On the Independent Evaluation Office at the Bank of England, the Bank is committed to independent evaluation. It is strengthening the independence of the reviews that it commissions by moving to a model where it commissions external independent experts to lead the reviews.

I echo the noble Baroness, Lady Neville-Rolfe, in thanking the noble Baroness, Lady Noakes—and the noble Baroness, Lady Bowles, I should add—because we have a commitment from the FCA. If you want to be cynical about it, it may not be as fulsome a commitment as we might want, but it says that accountability, scrutiny and proportionality are central and it wants to support effective parliamentary scrutiny, which I think is where we are all coming from. I thank the noble Baroness and her committee for picking up the baton on this because we must all—Parliament and regulators, with the help of the Government where we can help—work together to have a regulatory environment that is effective and proportionate.

With that in mind, the Government do not think that at this stage further legislative amendments are helpful. I beg to move Amendment 31.

Amendment 31 agreed.