My Lords, I thank the Minister for his response. As I said, this is a probing amendment but also an attempt to indicate a framework that could be constructive, perhaps in particular around some of those issues on which all noble Lords have spoken. It covers things such as advertising; it may be that the regulation that one would want around advertising is that there cannot be any of it, but that would still be a regulation to prohibit. I feel that there is a need for an explanation of this vision, somehow all in one place. Yes, a lot of it could be extracted from today’s debate and the reassurances that have been given. However, it would be much better at the very least if it was all put together, perhaps in an Explanatory Memorandum. I still tend to think that there should be something in the Bill, even if more dilute than what I have proposed.
I very much thank the noble Baroness, Lady Drake. This inequality of arms is extremely important. When it comes to FCA consultations, how many members of the public respond? I am not sure whether I am a member of the public, but I have done it from time to time, and I can tell your Lordships that, even for somebody like myself who is well used to this kind of thing, the way it is composed and constructive can be jolly difficult to get your head around. It can be difficult to get yourself organised to put it in, unless you happen to be an industry specialist who does these kinds of things all the time. I therefore very much doubt that you get members of the public responding; you may get some of the consumer organisations, but again, I doubt that they have the familiarity that is necessary always to be able to nail the point.
As was also suggested, there is a tendency with consultations to weigh the responses: X% says this, and Y% says that, and the ones who struggle and have difficulty, which is always on the consumer side, are outweighed. An awful lot of people with a financial interest from the industry side will respond. There needs to be a better mechanism for communicating with, if you like, the public and their representatives. One thing that could be done is for the FCA to obligingly inform Parliament when it is coming out with its consultations. I do not camp on the FCA’s website, looking for its consultations, and if I do not, I do not know how many members of the public will. This is a work in progress. I have to come back again on the costs.
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In my previous life as chair of the Economic and Monetary Affairs Committee in the European Parliament, I had a calculator that showed the effects of charges and commissions on a variety of funds at the various levels. Every five years, the charges were the effect of a stock market crash. The end computation was that more money had been extracted in charges and commissions than had built up as added profit in the pensions. This was about fund management in general rather than pensions, but the same point applies, and probably even more so. To get somewhere with the projections is the only way to show the member of the public—the saver—the effect of these charges. It does not look very much when it is a fraction of a percent, other things happen only when there is overperformance and there has been a lot of improvement in this area, but the deductions that your end value suffers are still extraordinarily high. This is not a subject that I intend to let go easily. Work should be done to make this more publicly available.
I doubt that an industry delivery group will say how wonderfully easy it is, but maybe something like the calculator that I had could be put up there, because that shows how these fractions add up over 20 or 30 years. I welcome the reassurances and agree with the noble Earl that there is no difference in the objectives. For now, I will beg leave to withdraw my amendment, but I may wish to return to it at Report.