Member

Thirdly—I am rushing at this stage—it creates a structural weakness that could erode consumer protection over time without Parliament having decided that it should be weakened. If a future regulatory shift dilutes high-level protection, the consumer duty being the obvious example, then because Cause 8 ties FOS’s decision-making to FCA rules, consumers’ access to address would shrink automatically alongside it. Parliament would have no way to intervene, short of primary legislation. Fourthly, it puts FOS out of step with every other consumer ombudsman scheme in the UK. Will the Minister address the absence of any thematic evidence to justify a change of this scale? Despite the scope of what is proposed and the risk that it carries for consumers, no public evidence of systematically problematic FOS decisions has been presented.