I thank the Minister for her very considerate response. It is a very complicated area, one that is in much flux, but I do not think that that should just be taken as a given, because the pressures, the pain and the anxiety that all this causes to vulnerable consumers—and also to ordinary people who are not necessarily too vulnerable in the conventional sense—are very substantial. We must always think of them as well as of the broader points that have been made in response to the amendments.
My central point, which, with respect, I think the Minister did not mention, is our increasing concern about the difference between saying that consumers’ interests are at the heart of the operation—which I absolutely accept is like a piece of rock built right through the FCA; you cannot have a conversation without it saying how much it puts consumers at the centre of it—and the reality that the measures that it
uses in its day-to-day work are about market efficiency and fairness. I am not saying that that is wrong: I am just saying that I am not entirely sure that this is a one-to-one fit. Establishing a market involving payday lenders that is efficient and fair, it may not remove the detriment that the remaining payers will be caused. I do not think that there is an easy answer to that; it is just something that we all should bear in mind when we think about how we regulate these matters.
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There is a corollary to that. I do not want to accuse the FCA in any sense on this matter, but it is clearly a strain for it, used as it is, with the experience that it has, in applying to commercial operators, to be faced with a substantial not-for-profit operation which is clearly running under completely different principles. The fact that StepChange is a charity means that the board is not the same as the board of a commercial company from whom it could reasonably expect a considerable load on each member of the board in terms of risk assessment, guidance, and establishing principles throughout the operation. Those would be the normal dialogue in any investigation or meeting with a commercial operator. They do not apply to a charity where the board is there to be a critical friend of the management and the bodies that it would expect to test whether its exhortations, practices and regulatory requirements are being met do not exist. We will get over that, and we are in dialogue with them.
My third point in my generic worry about this is that we are talking about relatively long lead times. There is the curious phrase of “landing slots” about when companies expect to land within the regulatory safe zone established by the FCA. What we are supposed to be doing while we are flapping outside that zone, I do not know and do not wish to know. We are flapping around outside with interim authorisation, but so is every other player in this operation. No one yet has authorisation in the sector, so there are lots of people for whom the end result will be that they are unacceptable who will probably be exiting the market, and have yet to be fully assessed. Obviously, that takes time, but our landing zone is not until spring 2016, which is a long time for vulnerable people to have to worry about whether their debts are being authorised, their plans are being underwritten and their support is being provided by an authorised person. That is the context out there.
I hear what the Minister says. I am grateful to her for her interest and support for the work that StepChange is doing. She mentioned a meeting between the Treasury and the FCA. If there is anything that I or my colleagues at StepChange can do to contribute to that, we stand ready and willing to do so. Perhaps that message can be passed back.
Having heard what the Minister said, I am happy to withdraw the amendment, but I hope that the Government will keep an eye on this issue, because it bears considerable investment. With that, I beg leave to withdraw the amendment.