Consumer Credit Bill

My Lords, what the noble Lord, Lord Borrie, has just said sounds plausible, and I am sure that it would read plausibly, but it is wrong. This is an important point of principle and I hope that my noble friends on the Front Bench and the Liberal Democrats will press the matter further, because I find it difficult to accept that the Government can have it both ways. The Minister has been very eloquent in arguing that detailed specification is not required in the Bill, either for certain duties and responsibilities of the OFT or in other aspects of the Bill. The noble Lord, Lord Borrie, referred to the appeals procedure and the Minister referred to the Enterprise Act. But the guidance to be issued by the OFT is extremely important and should be indirectly questioned in Parliament. That can be done only if the Secretary of State takes responsibility for the approval of that guidance so that he can be accountable to Parliament. I do not like the trend, particularly with the greater powers being given to the OFT, of guidance being issued, undoubtedly after a lot of consultation, without an audit trail, a sense of accountability and a reality of accountability to Parliament. That is why I support the amendment and hope that it is pressed further at a later stage.