Financial Guidance and Claims Bill [HL] Debate
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Lord Stevenson of Balmacara
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Financial Guidance and Claims Bill [HL]
Lord Stevenson of Balmacara ExcerptsMonday 11th September 2017
(7 years, 3 months ago)
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Lord Stevenson of Balmacara (Lab)
My Lords, in moving Amendment 49 I shall speak also to Amendments 54 and 55 in this group. I am grateful to the noble Baroness, Lady Meacher, for adding her name to the first of those amendments.
The amendments continue the debate we have had about standards and seek to draw out a response. In that sense they are probing amendments and I do not expect them to be accepted as they stand. They are probing in the sense that they are trying to draw out more clearly what standard setting will involve. As has been mentioned, Clause 6 states simply:
“The single financial guidance body must from time to time set standards to be complied with”,
but does not specify what the standards are. Are they about dress codes or eating habits? Presumably they relate to the more detailed work of how it deals with its customers. I would hope that it is the latter but that does not exclude the former. A word of comfort from the Dispatch Box might ease troubled concerns outside.
The underlying problem is that for many of the bodies to which the standard setting will apply there is an existing regulatory framework operated by the FCA and therefore we are in danger of seeing dual regulatory powers. This is not just a trivial point about bureaucracy. In a recent report from the StepChange Debt Charity, in which I have already declared my interest, the chairman points out that the arrangement under which it receives its regulatory authority from the FCA has added 7% to the charity’s costs. This is a body with a £20 million turnover so it is a significant sum for getting itself ready, and rightly so, to be regulated by a body. To think that more of the money that StepChange raises for charitable purposes will have to be spent on satisfying another regulatory body would seem to be unusually onerous.
To be clear on what we would like the Government to say on this point, there is a case for something to be said at the Dispatch Box which makes it clear that the SFGB’s currently broad and largely unconstrained regulatory powers should be moderated by some sort of framework. We propose in our amendment that the regulation should be specifically addressed to a commissioning framework, because certainly in the debt space the intention is that the bodies concerned will be commissioned to provide particular services which the single body thinks should be available. We have taken wording from other legislation which suggests that the commissioning framework should be based on the competencies of the provider against which it will satisfy itself when it commissions and procures services. That would give a route in towards the thinking here.
When we are talking about charities, we are also talking about those that are regulated separately by the charities regulator on certain aspects of their work. Again it is important to recognise that additional and triple regulation would be unnecessary.
The powers will come mainly from the FCA. Once more, it would be helpful if the Minister could respond to the likelihood of that. There is only one comparable situation at the moment where the FCA regulates bodies operating in the debt space, and indeed it has just completed a full review of a number of them. At the same time it has been asked to look at the current rules as they affect the Money Advice Service. When the authority did that, it said that it would not review or comment on the particular requirements of MAS—here I give a sense of its comments—because it felt that its standards were sufficiently high to encompass anything that would be involved in MAS and relating to the bodies that it funded. Again, what that would mean in practice is a little uncertain and perhaps the Minister will think about whether it will be necessary to get a better specification from the FCA, which perhaps could be done through correspondence, of the type of regulatory framework it thought it would be looking for from the SFGB, at which levels there would be any overlap, and in what sense any additional work would be needed. In short, we are looking for legislation that is concise and focused along with a broader statement of practice prior to the passing of the Bill which would give us more detail on how the body will operate in practice and the impact and burdens on those bodies it commissions. I beg to move.
The Lord Speaker (Lord Fowler)
My Lords, I should inform the Committee that if this amendment is agreed to, I cannot call Amendment 50 by reason of pre-emption.
Lord Stevenson of Balmacara
I thank the Minister for a very full response. There were points where I felt she was in a bit of a hole and continuing to dig, and we may well have to come back to them. They were largely in response to the rather sharp questions posed by the noble Lord, Lord Deben, on which I do not think we have reached the end of the journey. We will need to come back to this.
It was very nice to see support from the noble Earl, Lord Kinnoull, and the noble Baroness, Lady Altmann, on different aspects of the same thing. As the noble Earl said, the fact that we have eight amendments in this group and a few more in the next on this area shows that this part of the Bill is not as well baked as some of the rest of it. There are areas that we have some concerns about, but I will read what was said in Hansard and we can perhaps pick up some of the points in correspondence before we come back on Report.
I wonder, however, whether we are not in a bit of a car crash—a hard word to use. I do not think the Bill has quite taken the trick here on a number of the issues that have surfaced. First, we have a body called the FCA which has responsibility for overseeing operations in the financial services area, but its remit, as we have pointed out on a number of occasions, has a different focus from that which we expect for the SFGB. With its overriding responsibility for making sure that markets are fair and that competitive markets are operating in those areas, it is not right for the Minister to say that the FCA can be relied on to have regard to the position of consumers. Indeed, our debate last Wednesday on amendments on exactly this point, which were supported right around the Committee, pointed out a number of glaring exceptions to the feeling that all was all right in this world in relation to those who are generally called vulnerable customers. These range across those not included in any financial arrangements at the moment, whether by desire, function or mental or physical disability. These people who do not currently participate, cannot currently participate and are not finding the services and opportunities for participating that they would expect to find will not be served if the end result of this operation is the FCA’s mode of operating and not what we currently have, which is much more consumer-led. We shall have to come back to that.
On what the standards are doing and how they are operating, enough has been said in Committee to feel that there is a bit of uncertainty about exactly what is being done here. In pensions, where there is direct provision, the standards are internal and operating, but they will not be the same in the debt space, where very expert bodies, which, as the Minister said, have been doing this work for some 30 years, will not take it kindly if some new body, although it has a history as a previous organisation, starts setting standards without consultation and without some sort of specification. I hope the wording is sufficient to take that point.
If we are in a situation where all the services are to be done under existing regulations, does that imply that bodies not currently in the UK might also have to be offered the chance to bid for these services? Presumably this will be done under the EU procurement directives. Is that right? Will the Minister respond to me on that point, not necessarily today, but perhaps in writing? It changes the ball game if we are talking not about Citizens Advice but about a body with a similar but different name and perhaps the German republic offering to operate it because it is able to fulfil a document that has been prepared to elicit bids at an appropriate price. We might be heading for a bit of trouble.
Finally, there is advice and counselling. I am on a bit of a journey here, I confess. I was more firmly in favour of leaving things as they are when I started my work on this Bill than I am now. I am beginning to think there is a problem here because I do not think the consumer is with us in the way the Bill is being drafted. I do not think a consumer has the same expectation about the words “information”, “advice” and “counselling” as is displayed in the Bill, and I appeal to Ministers to use the time between now and Report to reflect quite hard on this. We have to be where the consumer is. If we are saying that there ought to be a body that can deal with people’s genuine need for information, advice or counselling about their financial situation—and I agree with that—we should not set preconditions about how, in what manner and under what regulatory framework that information, guidance and advice is to be delivered. There may be necessary constraints on what can be said, but it is important that we try to align this more closely with people’s motivations when they come forward. That is the first point.
The second point is that this body will not be the success that we all hope it will be if it cannot give the information that is being sought promptly and efficiently to the person making the request. We have already established that that will be difficult in the pensions area from day one, but we also expressed our hope, at Second Reading and subsequently in amendments, that it would be looked at very closely and, indeed, that the pensions dashboard would be under the ownership and control of that body.
Baroness Buscombe
It is very helpful that the noble Lord, Lord Stevenson, is giving such a full reply, but perhaps I may ask one question. He made a very interesting point in day two in Committee, saying that the whole problem of debt advice and guidance would have been resolved if we had gone down the path of having two separate bodies, one giving guidance and one giving advice. Is he therefore suggesting that if there were one single financial guidance body, we should expect that one person would have the expertise—for the convenience, in a sense, of the customer—to give all kinds of guidance and advice to one person, so that they would not have to be directed to other people to talk about specific issues?
Lord Stevenson of Balmacara
That is a very good question. I think the answer is that yes, I am saying that; but I am also saying that it is probably impossible. I want to unpick that slightly. It would be fantastic if somebody approaching a body—let us call it the single financial body—primarily for debt advice also had embedded in their series of questions about their unmanageable debts the possibility of going in, or not going in, to an auto-enrolment situation for pensions, or has equity in a house that could be released which might resolve those things. At the moment, there is no way in which any one person could answer those questions effectively and efficiently. I think we all hope that that is where we will be at some point in the future, perhaps with much more use of automation and expert systems which would be able to take a person down a much longer and richer journey on these issues. If we build in barriers now to say, “Oh no, that’s guidance, not advice. We’re not going to go that way—we’re not even going to build a design or even think about how we might do that”, we will build in problems for ourselves further down the line.
We have a bit of time before the Bill goes to its next stages. I think I am asking whether we can use that time constructively to try to get really certain in our mind that, even if it is not the perfect solution, we are progressing with the right approach to this. As I said at the beginning of this little section, I had started on the basis that debt advice was straightforward and I understood it, and I was confident that I knew that because I had worked in the area. I am now not so sure. I have a feeling that we need a broader, higher-level definition that takes us a bit further down that route, where we think about things in terms of perhaps what is paid for and what is not paid for—anything which involves the offering up of clients’ money to be held in trust for them would need a completely different level of care and scrutiny and everything else.
Even with the simpler questions, such as whether people should join a new pension scheme or take money off an existing pension scheme—which will be real to the person asking them, although they may not be aware of the regulatory and other functions behind them—we might be making a terrible mistake. I am sorry to cast problems in what has already been a well-worked-through field—I know that a lot of this stuff has been discussed and debated ad nauseam and we should know better than this going forward—but my feeling is that we might have not quite got there yet, and we need a bit more help.
Baroness Buscombe
Before, I hope, the noble Lord withdraws his amendment, I should say that between last week and this week we in the department have constantly visited this issue, and we continue to do so. I do not want to test the patience of the Committee but I have further information on how this might work. I confirm that we will have meetings for all interested Peers so that we can discuss this in more detail between now and Report.
Lord Stevenson of Balmacara
I am grateful to the Minister for that. I think that those meetings will be helpful and useful. In the meantime, I beg leave to withdraw the amendment.
“(1) The single financial guidance body must monitor and report on its own and SFGB delivery partners’ compliance with the commissioning framework.”
Lord Stevenson of Balmacara
My Lords, this amendment is really the second half of the debate that we have just been having so I think we can skip quite a lot of the introductory part and get straight to the main point. The focus in the amendment in my name—I think other issues will be raised by the noble Baroness, Lady Kramer, and the noble Lord, Lord Sharkey, regarding their amendments, as they bear on the matter in a slightly different way—is Clause 7(2)(b), which states:
“The FCA must, at least once in every three years, carry out a review of … how the single financial guidance body is monitoring and enforcing the standards”.
I have searched reasonably hard through the documentation and I cannot find out what that enforcement is. At the heart of my amendment is a probe—actually, a direct question—to find out what the enforcement would be. Is this in relation to commissioned services being given some sort of penalty? Are fines to be involved? Is it going to involve reporting them to the FCA for a rap on the wrist or worse by some disciplinary body that the FCA might have? We do not know about that and I do not think we understand it. The sensibility is right—there is no point in having standards and asking that they be informed if you cannot do something if they are not informed—but we need a bit more detail before we can take what is in the Bill as being the right approach to this.
In Amendment 59, which I am speaking to but not moving at this stage, the assumption is made that some movement has taken place on earlier amendments and that the SFGB is doing the process of commissioning through a set of standards and a framework. That amendment has been withdrawn so it does not apply, but I still think the sensibility is right. If we are going to ask for reviews, they should be in relation to a specific issue. As it stands, Amendment 59 would give a slightly more flexible framework for that than every three years because it would relate to the success or otherwise of a judgment made by the SFGB on whether or not the work it is doing was going well, and therefore it would have a bit more teeth. I beg to move.
Lord Sharkey (LD)
My Lords, I will speak very briefly to Amendments 58, 60 and 61, tabled by my noble friend Lady Kramer and me. We agree with the Bill’s requirement in Clause 7(1) that the SFGB must monitor its own compliance with standards and that of its delivery partners. However, we feel that the results of this monitoring should be in the public domain; in fact, it would be extraordinary if they were not. Our Amendment 58 would rectify what seems to be an omission. It says simply that the SFGB must produce and place in the public domain an annual report of its assessment of its own, and its delivery partners’, compliance with the standards. We hope that this is completely uncontroversial and the Minister will feel able to accept the amendment.
Amendment 60 is equally simple and straightforward. In Clause 7, dealing with the monitoring and enforcement of standards, and in subsection (3), the Bill lists those to whom the FCA must provide a report on its review of whether the standards continue to be appropriate and how the SFGB is monitoring and enforcing those standards.
The Bill specifies that the FCA must provide its report to the SFGB and to the Secretary of State, but there is no mention of Parliament and we think there should be. Parliament will have set up the SFGB. It is a matter of transparency and accountability that Parliament should also have sight of the FCA’s report. Our amendment simply adds Parliament to the list of those to whom the FCA must provide its report.
In Clause 7(4), the Bill provides that the FCA’s report may contain recommendations to the SFGB. But that is it—the Bill does not say what should happen when the SFGB is in receipt of these recommendations. Clearly, something should happen and it should happen in public. Our Amendment 61 provides for this. It simply says that when the SFGB is in receipt of recommendations in an FCA report on its review, the SFGB must then publish a substantive response within three months to any recommendations made by the FCA.
The changes proposed, I hope, in all three amendments are completely uncontroversial. They are nothing more than an application of the principles of transparency and accountability to this new public body. We hope that the Minister will see their merits and feel able to accept them.
Baroness Buscombe
My Lords, I thank noble Lords for Amendments 57 to 61. Clause 7 requires the single financial guidance body to monitor and ensure compliance with its standards. It requires the Financial Conduct Authority to periodically review the standards, and how the body is monitoring and enforcing those standards. After completing its review, the FCA is required to provide a report for the single financial guidance body and the Secretary of State. Once again, I reassure the Committee that the standards will not apply to all debt advice providers. These standards will apply only to the body itself and its delivery partners.
First, I shall address the Amendments 57 and 59, tabled by the noble Lord, Lord Stevenson. I have made the argument previously that the framework set out in Clauses 6 and 7—for the body to set and monitor compliance with quality standards—is the right mechanism for assuring the quality of the services provided by or on behalf of the body. I refer the noble Lord to our discussion on Clause 6, where we discussed the proposed commissioning framework for the procurement of services. There I made the point that it was unnecessary specifically to require the body to publish a commissioning framework, since we would already expect the new body to publish its requirements and expectations, with adequate time for prospective delivery partners to prepare their propositions. I also pointed out that, when contracts are above a certain value, the body will be required to comply with the public contracts regulations, including the requirements to advertise its requirements and undertake a competitive tendering exercise. We hope that those expectations and requirements on the body meet the spirit of the noble Lord’s amendments.
The noble Lord’s proposed commissioning framework would also have replaced the requirement on the body to set and monitor compliance with quality standards. I made the argument that the standards actually play a different role to a commissioning framework, in that they will assure the quality of the services provided by the body and its delivery partners. The standards therefore play the crucial role of enabling members of the public to have confidence in the services that they receive.
I disagree with my noble friend Lord Trenchard that there is a concern about the possibility of the culture of the FCA becoming similar to the culture of the body—or maybe that would be a good thing. The body would not necessarily be influenced by the culture of the FCA, because it has a statutory duty to put the consumer first, as I said under the last set of amendments.
Lord Stevenson of Balmacara
I am sorry to interrupt, but I think that we have had this debate before. It is not right to say that the primary purpose of the FCA is to give the consumer pride of place. That is not what it says in the statute. We had endless discussions about this when this was going through the House, and the Government were adamant that it was an economic regulator and that the main focus had to be on the efficiency of the markets that it served. I think that the noble Baroness, Lady Kramer, made the same point on Wednesday. I understand why the Minister would want to say that, and I am sure from discussions with the FCA that it has regard to consumers and their interests—but there is no consumer representative on the board of the FCA. It has a consumer panel, but it is not allowed to have a main position. I think that there is a representative with an Australian background on the board who has some expertise in consumer affairs, but that is not the same thing as building in from the bottom and ensuring throughout the work of the FCA that it focuses on the consumer, which is the impression that the Minister gives.
Lord Stevenson of Balmacara
I thank the Minister for her very full reply, which I look forward to reading in detail in Hansard; we will consider what she has said. The noble Viscount, Lord Trenchard, made a rather good point on a common theme which we need to come back to. Two regulators doubling up—having a second one—is a worry, and we need to make sure that the statute reflects the difference between the two, if there is to be one. He is right to make that point. I thank the noble Baroness, Lady Meacher, for her support. We anticipated it when discussing a previous amendment, when she was not present, so her name is recorded in Hansard in that regard.
What I am missing from the long response—I mean that in a positive sense; I welcome a long response—is a sense of what enforcement there is in practice. I would be grateful if the Minister wrote to me about that. It is important for people hoping to engage with the SFGB that they should understand what they are going into. The relevant word is in the Bill.
I return to the difference between the FCA and the SFGB in terms of consumers. I am grateful to my noble friend Lord McKenzie for providing me with the evidence submitted by the Financial Conduct Authority to the Lords committee dealing with financial inclusion, which stated that when considering what degree of protection for consumers may be appropriate, the FCA must have regard to, among other things, the differing degrees of experience and expertise of different consumers. Therefore, we are not talking about a single response. We are also required to have regard to the general principle that consumers should take responsibility for their decisions. That is hardly putting consumers at the very forefront of the decisions. The FCA recognised that consumers can do this only if they have access to appropriate financial services that meet their changing needs, and that under its objective to secure an appropriate degree of protection for consumers, regard must be had to consumers’ need for timely provision of information and advice that is accurate and fit for purpose. In other words, this is entirely about market-facing competition and efficiency, not those in vulnerable circumstances. In the interim, I beg leave to withdraw the amendment.
Lord Stevenson of Balmacara
My Lords, I shall speak also to Amendments 65 and 66. They bear on the financing arrangements for the new single financial guidance body. We have talked about how the money is to be raised and the change from the current arrangements, with a move away from a straight levy system within the financial sector to an arrangement whereby money goes to the Government and into the Consolidated Fund before being paid out in grants.
The amendments are not meant to be taken word for word, but probe the way in which the case for this funding is built up. Amendment 64 would make sure that the single financial body did not underestimate the amount of money it would require by virtue of not having sufficient information to hand about the costs that it would be likely to have to meet given the aspirations for it. An earlier amendment referred to assessing this on the basis of the likely number of those in need of financial advice being the main element in building up the funding envelope. Obviously, there is difficulty in trying to assess that. This amendment adds a little more in terms of the consultation and guidance.
It would be to the advantage of the Bill if it provided for a little more accountability for the funding received. We set out in the amendments the specifics, which may well be covered by other points that the Minister may raise when she responds. At the moment, there is nothing very much in Bill about monitoring the use of the funding and making sure that the information gathered is published, particularly for Parliament, so that due scrutiny can take place.
Amendment 66 deals with how funding is to be established for the national regions. There is nothing exceptional in what is being said in terms of the mechanics—I am sure that the Bill is drafted with due concern for the proprieties involved. A number of the bodies that will be in partnership with the SFGB, or funded by it, already operate in Scotland, Wales and Northern Ireland and offer direct services themselves. If the Treasury is to get information on that, as is specified in Clause 11(1), it will need information which it is not clear that it will be able to get—or, if it is, I have not spotted it—on the costs and expenses of the existing bodies operating existing services in Scotland, Wales and Northern Ireland and how that matches what the devolved Parliaments think should be spent there. There is a lacuna there on which I look forward to hearing a response. I beg to move.
Lord Young of Cookham
My Lords, it is the co-pilot again. I thank the noble Lord for tabling these amendments to Clauses 8 and 11. Clause 8 provides for the Secretary of State to give financial assistance to the single financial guidance body; Clauses 9 and 10 provide for those expenses to be recovered respectively from the levy on pension schemes and through the financial services levy.
At Second Reading and in earlier Committee debates, the noble Lord has questioned this funding framework and the money trail, suggesting that it represents a fundamental change in the way in which things are done currently and that it would radically alter the way in which people operate, particularly in respect of the services provided by MAS. I am not sure that the changes are that fundamental, but, in any case, we think that they are both necessary and beneficial.
One criticism of MAS made by the Farnish review was that it lacked accountability for the activities it delivered and the money spent. As the noble Lord suggested, we need to learn lessons from our experience with MAS. These funding clauses provide a basis for strong accountability and governance arrangements. We want the body to have a clear focus on undertaking its statutory functions. As happens now with the existing organisations, the body will prepare an annual business plan setting out its planned activities and the associated budget required to deliver its proposals. That plan will be discussed and agreed with the DWP.
Lord Stevenson of Balmacara
I am very grateful to Minister in his capacity as co-pilot, first for the ministerial looping of the loop to allow him to correct the earlier misstatement about the role of reserves in NDPBs. We were concerned about that issue and we would have come back to it, so I am grateful to have the clarification that in certain circumstances—although he did not disclose them—it is possible for NDPBs to hold reserves. That accords with our experience.
Flying has lots of problems and hazards, and one is undoubtedly fog. The Minister did well when he was soaring high on some of the more general points, and I am very grateful to him for his full responses on the way the funding will operate. When they are read in Hansard they will be as clear as daylight at midday, and I will be very happy with them, but two things occur to me. First, we still have not had a response to a point raised earlier—not explicitly in today’s debate, but it is still part of it—about the way the financing system has been constructed. While many of the companies that will receive the benefits of better advice, more financial inclusion, less financial exclusion and all that goes with that will be funding the SFGB, which will be operating many of the services, not all the companies will. I am thinking particularly about the utility companies, which we have discussed already, for which substantial work is done to help their customers who get into debt problems. I know directly of a number of such cases. I do not want to overegg the case, but increasingly, other organisations such as HMRC, DWP and local authorities are involved in trying to sort out debt problems and do not currently contribute to the way that is funded. The levy system is a clean and efficient way of doing it, and I understand all the points made by the Minister, but it misses out a sort of “polluter pays” principle, and it might have been rather more satisfying had we been able to include that. Individual organisations and companies receive funding from other bodies involved in debt advice and other money guidance operations, but not all of them, and a little more pressure and help from the Government on this would have been helpful.
My second point in this general whinge on fog is that I am not sure whether we got to the bottom of where UK national bodies operating in Scotland, Wales or Northern Ireland—whether or not based in Scotland, Wales or Northern Ireland—are going to get their funding from. If Scottish Ministers, for example, are shortly—is that the same as “soon”?—going to agree a system in which funding for debt advice operating in Scotland is to be funded through the Scottish block grant, does that mean that funding will not be available to UK national bodies such as the Money Advice Trust, which operates in Scotland but is currently funded from England? It is probably too complicated an issue to get an answer to at the Dispatch Box, so I would be very grateful if the Minister wrote to me. There is logic in trying to align geography with the funding settlement. But it would be perverse if, as a result of the good and effective work done by StepChange, which runs an office in Glasgow and in Wales and has a franchise arrangement in Northern Ireland, it was unable to be funded and had to be shut down or taken over by somebody else. I am sure that is not the intention, but it is an implication of what is being said.
The situation in Scotland is relatively well developed: there are good systems operating there, a long history of funding from the Scottish Government and local authorities for good debt advice, and good education and training for the advisers. I am sure that will continue and that the Scottish Government, who have always been in the lead on this, will want to see it continue. However, I hope it will not be at the expense, for instance, of work directly funded by MAS and the organisations themselves in Scotland in recent years.
Lord Young of Cookham
I have some in-flight refuelling. We are working with the devolved authorities on a final agreement and will write with more detail once discussions with the devolved authorities are completed.
Lord Stevenson of Balmacara
Gosh—that was worth waiting for! I look forward to any information that can be provided on a more direct basis, preferably soon, but I think we have covered enough ground there.
Finally, some good points were made about the need for flexible funding solutions when there are crises, and I would like to read those in Hansard. This is very recent history, so it will be in the forefront of the minds of the bodies concerned. When the FCA was going through an accreditation process regarding debt management companies, it became fairly clear that about 50% of them were going to go out of business, leaving many people with debt management plans paid for through these commercial companies, but which those companies were going to withdraw from. MAS was able to organise substantial additional funding to all the bodies concerned to cope with that. That would not neatly fit into an annual financial cycle, so it is important that we have flexibility at the edges. I am completely open to that being done by government grant or by the holding of reserves, but it is important that it be built into the systems. However, as long as that point has been taken, and I gather it has been, I beg leave to withdraw the amendment.