Financial Services Bill

My Lords, other noble Lords may have seen the briefing from the British Bankers’ Association that deals with the point made by my noble friend and the issue that her amendment seeks to address. The association says, inter alia, that the provision of a financial stability objective should not be taken as a licence for the FSA to place unreasonable information demands on banks and that there will be a need for full and open dialogue on what further data capture and reporting requirements this may involve. It says that the provision should not be taken as a licence for the FSA to act other than on the basis of proportionate action, based on established need, and a full understanding of the consequences of its action. This is clearly an issue that concerns the British Bankers’ Association a great deal. The amendment that my noble friend moved would go a long way towards ensuring that these concerns are addressed because of the way which she requires the FSA to plan and prepare and to explain why it will act in a proportionate way.