My Lords, the PCBS always envisaged a two-tier system, one for senior persons where prior registration would be required, and the other for staff below that who are not senior persons but who are nevertheless capable of inflicting damage to the bank, its customers or its shareholders. We felt that the original provisions made for the upper tier were broadly okay, although there were one or two refinements about what a bank is. However, we thought that the provision made for the second tier was too vague. I therefore welcome these amendments, which bring much greater focus to who is covered and what the obligations are.
There are two loose ends in this, which do not need to be concluded this evening. The first is that there are a number of functions in banks for which the APP—the approved persons regime—will be retained, namely the submitters of LIBOR numbers and those who have responsibility for money-laundering. It might be worth considering at some point whether instead of having three schemes for banks—the two new ones and the old one—they can all be consolidated. Finally, there is also the question of whether, in the fullness of time, a decision needs to be made on whether to continue with the old approved persons regime, with all the faults that we identified, in the rest of the financial services sector.