Financial Services and Markets Act 2000 (Amendments to Part 18A etc.) Regulations 2010

My Lords, first, I declare my interest as a director of an investment management firm regulated by the FSA. I was very intrigued by the comments made by the noble Baroness, Lady Noakes, about the opportunity cost of preparing for a debate such as this. I feel my meter now running really fast. I am not sure whether my hourly rate is as high as that of a former leading partner of KPMG, but perhaps I can compare notes with the noble Baroness later. We do not have serious worries about the first set of regulations, but I, too, would be interested to know how many times this procedure is likely to be invoked. I am having difficulty getting my head round exactly what pieces of paper we are talking about although I know obviously that we are talking about OTC products. Perhaps I am rather old-fashioned but I would find it helpful to know what instruments the FSA is concerned about. Clearly, there was not a large number of responses to the Treasury consultation. Broadly speaking, we on these Benches do not have serious concerns but we would be interested in receiving a little more explanation. We strongly support the principle behind the second set of regulations. The report of Professor Davies makes a very good case. Too many issuers have played fast and loose and they should be made to take their responsibilities more seriously in respect of damage or loss suffered as a consequence of giving inaccurate, false or misleading information. My only question is, if it is right to introduce this measure—we believe that it is—why has it taken so long to do it? The consultation closed in October 2008—almost 18 months ago—so why has it taken so long to introduce something which is widely supported and concerns the important issue of consumer and investor protection? But subject to that, we welcome the regulations.