Dormant Bank and Building Society Accounts Bill [HL]

I would like to explore with the Minister what information the reclaim fund has to have. It is common ground that if there is a dispute about the nature of the amount being repaid, or possibly to whom it must be repaid, the reclaim fund would have to have that information. However, the scheme says the banks will pass dormant account money over to the fund and will then tell it when the bank thinks a repayment is due, which may or may not be the same amount as originally handed over. That scheme cannot effectively operate within the reclaim fund as a proper basis for it to spend money on repayment. The fund should have records of which dormant account money it has taken over, so that when an amount is repaid it can knock that off the list. The fund cannot simply hand over all record-keeping to banks and trust anything that a bank gives to it at a later stage about what that bank thinks should be repaid. If the reclaim fund is to be a responsible body in relation to the money it has to keep back for repayments, it is inevitable that it has to have information—otherwise it can never validate what it is being asked to repay. While the scheme sounds quite nice, with the banks handling the information, how does the reclaim fund check that information before paying? It seems to me that the fund has duties. If I were still an auditor and advising a company such as a reclaim fund on the proper sorts of controls that needed to exist, I would say that it could not have a proper system of internal control that did not identify the potential obligations that it took on—which would have to be on a named basis—and it would then have the ability to match those off when repayments were made. I simply cannot conceive of a body keeping proper accounting records without knowing what they are all about. Perhaps the Minister can explain.