In the two previous groups, I raised pension credit, and it is notable that the noble Viscount the Minister has not responded on that point. As such, my automatic assumption is that he believes that the implementation of these powers will deter people from seeking pension credit, which is contrary to the Government’s declared policy to encourage people. I mention that in passing, given this opportunity.
My other moan is about the impact assessment; there is none. I do not like the impact assessment that we have. It is a totally impenetrable and meaningless document, which is clearly there just as a matter of form rather than as a serious attempt to try to inform participants in these debates about what is in the Bill and what impact it will have on people and organisations.
My specific points are broadly in line with the points raised by UK Finance, the overall organisation for financial organisations, including banks and insurance companies, which continues to have serious concerns about these provisions. I think we should listen carefully to what it says. In particular, if we are going to have these powers then, in line with the amendments tabled by my noble friend Lady Sherlock, we have to make sure that they are introduced in an effective way that appreciates the vulnerabilities of customers.
4.30 pm
UK Finance is concerned about the design and proportionality of these proposals, the impact on vulnerable customers and financial organisations’ consumer duty, which was introduced under wide-ranging powers under other Acts of Parliament, to consider and look after the interests of their customers. To what extent does this power run across their consumer duty? Any involvement in implementing these powers has to comply with their consumer duty.
UK Finance also emphasises that the one-off aspect of these proposals is bad. It is unhappy that it is a one-off; this should be part of an overall strategy to deal with fraud and financial misunderstandings within the sector. Just picking it off as one particular aspect, when it is a much wider issue, is a matter of concern to it. It is also concerned—perhaps this is something I would urge my noble friend to think about when we come back to this issue on Report, which I am sure we will—that charities and social organisations that represent people who are less able because of income or background to cope with these issues will be involved in the consultation on this code of practice. I am totally in favour of my noble friend’s proposals, but I suggest that consultation needs to go somewhat wider than the list in the amendment.