Charges are also quantifiable. The aim, as we have set out very clearly, is to cover all components of the total cost of the loan.
The noble Lord, Lord Higgins, asked about the high charges that high street banks sometimes impose. Issues there can be investigated by the FCA and no doubt it may well wish to do so.
The noble Lord, Lord Mitchell, asked a number of questions. I first congratulate him and my noble friend Lord Sharkey on the persistence with which they have pursued this issue, bringing before the House evidence of what is really happening in the market and helping everyone involved in the process to gain a better understanding of the scale of the problem. I can confirm that the government amendment does what it says in that the FCA will not have any option but to make rules. It has to do it. The “must” is a real “must”. In terms of the powers that the Treasury will have, the purpose here is to ensure that the Treasury has an input into the consultation and development of the policy by the FCA. However, we have been very clear that the primary responsibility must rest with one body and that the appropriate body is the FCA. I will come back to the noble Lord’s point on timing in a moment.
The noble Baroness, Lady Cohen, said that she wished that credit unions could be more like payday loan companies. I think many noble Lords would share that view but, sadly, they have some way to go before they get into that position.
10.30 pm
The noble Lords, Lord Mitchell and Lord Eatwell, and the right reverend Prelate the Bishop of Birmingham, urged the FCA to go quicker. The FCA will go as quickly as it can. Our amendment requires it to have the new system in place no later than the beginning of January. If it proves possible to do it do it earlier, certainly if it were possible to do it before Christmas, I know that the FCA will do so, and will use its best endeavours to bring forward these proposals as quickly as possible. Certainly, if we are going to include within the system features such as a real-time database, I am afraid that this cannot be done very quickly. Everybody has seen the success and failure both of Governments and other organisations to introduce IT systems very quickly. The thought that one can do this within a matter of weeks prior to consultation, possibly with no consultation, seems to me totally fanciful.
I end by saying—because I think a number of noble Lords slightly question this—that the Government and the FCA are absolutely committed to getting this system in place as soon as they possibly can. The FCA has said it is going to do it. It has already set a very tight timetable. I understand that when the system was introduced in Florida it took longer or at least as long as we are proposing to do it here. There is no lack of commitment to do it but we want to do it right. We want it to work. We do not want to have to change it as soon as we have implemented it because we found we rushed it and it has not worked. That is why the FCA has come forward with a speedy but deliberative approach. We think that makes absolute sense. That is why the deadline is in our amendment. I commend our amendment to the House.