Member

These prior steps are modest and what you would expect; they are proportionate and entirely consistent with the Government’s aims. If a voluntary route is working, the evidence will show it. If regulations are needed, these safeguards ensure that they are proportionate and do not undermine fiduciary duty or competition. If the Government are confident in their policy—not the ABI’s policy—they should have no difficultly in meeting these prior steps. If they cannot meet them, they should not be exercising the power.