Lord Vaux of Harrowden (CB)

My Lords, I thank all noble Lords who have taken part in this debate and for their support for my amendments. We tabled these cost amendments primarily because we do not know what the costs are but we know that things will evolve in the future, and therefore it seems sensible that the independent reviewer should at the very least have a look at that. The Minister used the word “could”, but I would still like that to be “should”. We may well come back to that point at a later date. The Minister mentioned that, when we are sending an EVN in, we are not requiring the banks to look into the data that is being provided to the DWP. That is naive. I do not think that any bank will ever just trawl through, pull a load of data out and send it up without checking it, because there are liabilities here to the banks. If they send a load of stuff up that is incorrect and people suffer as a result, guess who will end up getting it in the neck? It will be the bank that provided the incorrect data. It comes back to the debate we had earlier on the amendment in the name of the noble Lord, Lord Sikka, about who is liable. That is slightly naive; there are genuine, real costs here. The banks will be required to review, check and make sure that what they are providing does not cause them problems with their customers, hence the questions on breach of duty of care. With respect to Amendment 89C—the UK Finance amendment, if we want to call it that—the Minister said that she would try to persuade me. I need to look at what she said more closely to see whether I have been persuaded. However, to be brutally honest, it is not me she needs to persuade—it is UK Finance. I urge her to have further discussions with UK Finance as soon as possible on this matter, because it seems that it is still exercising financial institutions and the industry. There is a lot in the impact assessment to say that they should not have a problem with this, and the Minister has given an explanation as to why she does not think they should, but they are still worried about it, so the department and the Minister still have work to do to make sure that UK Finance is comfortable. If it is uncomfortable, that is not a good way to start this relationship. The Minister said that the job of the FCA was not to endorse government guidance, and I agree, but that is not what I was asking. The FCA should provide guidance to the industry that says, “If you provide this information, it does or does not have this effect”. It is for the FCA to give guidance in that respect, rather than endorsing what government guidance says. It ought to be proactive. To be honest, it should be involved in this process to make sure that it is happy that this does not cause a problem to the industry, and give guidance to the industry accordingly. Again, I hope that that discussion is going on. I touch, finally, on the debanking issue, because it has been raised. It is a bit of a misnomer. The bigger concern to me is not that people’s bank accounts will be withdrawn—that is unlikely. More likely is that banks will become less willing to provide future bank accounts. It is not active debanking, but a slow erosion of willingness to provide services to particular groups of people. We have seen for ourselves as PEPs that banks do not like to provide us services as a result of the PEP rules. It will not be any different here. If we make it more difficult and expensive to provide accounts, it will slowly erode over time. It is not debanking in the sense of the closing down of Nigel Farage’s bank account approach, but more the erosion that I worry about. Having said all that, I think that we will come back to one or two of these issues at the next stage. I beg leave to withdraw the amendment.