Joint Committee on Financial Services and Markets Minutes of Evidence

Examination of witnesses (Questions 339 - 359)




  339.  Good afternoon. Thank you all very much for coming to this session. I am sorry we are a little late. As you know we have been having a number of sessions with groups of people. Basically we have been taking the Treasury's Progress Report as the document that we have been investigating and asking how far it goes to meet people's concerns in relation to the original consultation document that we had from the Treasury. We have been trying to major on particular issues in each of these sessions but we have also recognised that people will sometimes wish to touch on other things as this is their only opportunity to come and speak to the Committee. Although the main theme today is accountability, and many of our questions will be on this subject of accountability, we are happy also for people to make points on other issues if they wish. I would like to begin by asking you each to introduce yourselves and to give us a brief statement of your views on this general subject. Maybe I will start with this side and Ms Saunders.
  (Ms Saunders)  Thank you very much, Chairman. My name is Barbara Saunders and I am Chair of the Financial Services Authority's Consumer Panel. The Consumer Panel was set up to be an independent voice for consumers within the FSA last November and as a Panel it has met on four occasions to date. My Panel welcomes the Government's announcement that the Bill will contain a statutory requirement for the FSA to establish such a Panel in future but it is far from clear whether the Government will also impose other requirements in addition to its stated objective that the Panel should assess performance in meeting consumer protection and consumer awareness objectives. We believe that the relevant clause in the Bill should actually secure the independence of the Panel, credibility which we believe will come from the members' appointment on merit following open competition, powers for the Panel to establish its own priorities, provide advice and make recommendations, conduct research which is fundamental and publish its views. In order to do that it will have to be provided with adequate human and financial resources to do the job. We believe that those things are important in addition to the requirement to contribute to the FSA's effectiveness assessments. On wider issues, Chairman, since this is my only opportunity, there are three things that I think are crucial. The first is that the rhetoric surrounding the one stop shop for financial services' regulation needs to be matched by a reality as perceived by consumers and investors in the retail market. That means that the definition of financial services should be wide enough to include mortgages and long term care within the scope of the FSA. It will, I believe, require a review of the interface with OPRA, the pensions' regulator, particularly in the context of stakeholder pensions. We would like to see the deletion of the caveat emptor clause from the Bill because we think it is unnecessary and it is already covered by the previous two provisions that the FSA should establish an appropriate degree of consumer protection having regard to the differing degrees of risk and the different expertise and experience of consumers. We think in the context of that the caveat emptor provision is unnecessary. Also we support the case which has already been made by the National Consumer Council and others that there should be a suitability and fitness for purpose requirement in the Bill, picking up on the existing PIA rules in that area.

  340.  Thank you very much. Dr McDonald?
  (Dr McDonald)  My name is Oonagh McDonald. I was formerly a board member of SIB and then the FSA for five years in total but I am here to give an entirely independent point of view today. The focus of my submission, which has already been received, to the Joint Committee is on the issue of enforcement and accountability, especially in the context of the European Convention on Human Rights. The main point I want to make is that sufficient safeguards in my opinion have been built into the Bill and in terms of subsequent Treasury announcements to ensure that the FSA continues to operate in a fair, open and accountable manner. In order to see that it is important to recognise some features which I think have been overlooked in the public debate, the continuity between the current system and the FSA under the new legislative regime. Some of the comment I have seen on the issue of accountability would lead one to suppose that an entirely new and uncontrollable regulatory monster is about to come into being, I do not think this is the case. Much has been learnt over the past decade or more about the process of regulation and indeed of enforcement and the experience and well tried practices of the past will be carried forward. The constraints on the FSA's actions, which applied in the past, and which have been shown to be effective, will apply in the future. I am happy to expand on some of those, for example the impact of the possibility of judicial review. One of those constraints, or as I would prefer to put it, contributions to the effectiveness of regulation is a public interest board. But to see why it is effective and can be effective it is important to understand how it operates and in my experience an important part of the effectiveness of the board is that it operates as a unitary board which in turn helps to ensure that it is a strong and united board. As I said, I will be quite happy to elaborate on any of these points if the Committee desires.

  341.  Thank you very much. Mr Telford?
  (Mr Telford)  Thank you, my Lord Chairman. My name is Philip Telford, I am a Senior Policy Researcher with the Consumers' Association. With me is my colleague Francesca Arcidiaco who is our Senior Public Affairs Officer working on personal finance and financial services. I would like to thank you for the opportunity you have given us to present evidence today about the proposed arrangements for accountability of the FSA. As you may imagine this is a theme of great interest to us, accountability of the regulator to consumers and to investors. I would like to say at the outset that we see a key role for consumer involvement at the very heart of regulation, and at the heart of the regulatory structure. Of the FSA's four current statutory objectives, two of them public awareness and the protection of consumers relate specifically to consumer issues. Set against this background, consumer representation, consumer involvement and accountability to consumers is of course vital. We have certainly been pleased with the prompt move by the regulator to establish the FSA Consumer Panel. Certainly we are encouraged by the approach we have seen already of the Panel, as we were by the work we saw from the predecessor of that body, the PIA Consumer Panel. However, there are certainly no grounds for complacency. We do remember that although the Financial Services Act was passed in 1986 it took until 1995 before we had a Consumer Panel at all and then only for one of the regulators, the Personal Investment Authority. For too long the voice of the consumer was marginalised in the regulatory structure. We are convinced that it is vital we put in place a robust system of consumer involvement. We wholeheartedly welcome the fact that the Consumer Panel will be on a statutory basis. But more than this we think it must have an independent budget, its own team of staff. It must be free to make public statements and there must be a requirement for the FSA Board to make formal responses to the Panel's reports and research. The Panel should also be able to undertake research across a broad range of areas and not be restricted to regulated activities. More than this, the Panel is not the only conduit for consumer involvement and a consumer voice. It is vital that they and the FSA Board involve consumer organisations and individual experts in formal and informal consultation. We would also like to see the use of consumer impact statements by the regulator in the same way that they will issue financial impact statements. We fully support the fact that appointments to the FSA Board should be made in accordance with the Nolan Principles and clearly we would not take issue with the need to recruit competent and experienced individuals. However there should be a recognition that a balance is required between the interests of consumers and the demands of regulated firms. We really feel the time is long overdue for real commitment to consumer representation within the financial services industry.

  342.  Thank you very much. Before we move on to the questioning I would like to give Andrew Whittaker and David Roe the opportunity to say anything if they wish to. I realise that ten days has passed since we last met and you might have had a chance to reflect on some of the things that have gone on. We have had two papers from you which we will be making available in the next day or two, one of which deals with some of the comments you have made on some of the evidence we have received so far and the other gives your latest thoughts on the enforcement process. We will be discussing that again on Thursday and we will make those papers available. Is there anything you want to say, Andrew, today?
  (Mr Whittaker)  Nothing I would like to say at this stage.

  343.  David?
  (Mr Roe)  Thank you, Chairman. I would like to mention a couple of things now. I am sure they are things that we will come back to later but if I have an opportunity to say them now that will be fine. The first point is just to clarify the Government's intention as regards requiring the FSA to maintain Consumer and Practitioner Panels, which a couple of the witnesses have already mentioned. As the Economic Secretary implied in the evidence that she gave to the Committee, Ministers think it is desirable to allow some flexibility to develop the most effective arrangements over time. Therefore it is not the Government's intention to set out in detail in the Bill how the Panels should operate or be constituted. I would like also to say something, if I may, about a couple of other issues. One is the role of the non-executive members of the Board and the other is the question of the role of the Chief Executive and the Chairman, really by way of clarification. There will be a committee of the non-executive members of the Board, who will be in a majority. The chairman of this committee is to be appointed by the Treasury. The committee will have a special role in keeping under review whether the FSA is undertaking its functions in an economic and efficient way. This corresponds to the particular principle in clause 2(3)(a) of the Bill. Related to that, the committee will keep under review the adequacy of the FSA's internal financial controls. It will also determine the remuneration of the chairman and the executive members of the Board. Finally, there will be a requirement on the committee to report on the performance of its functions within the FSA's annual report. These functions of the non-executive committee will be in addition to the general responsibilities of the Board as a whole for seeing that the FSA acts in a way that is compatible with its statutory objectives. On the role of the Chairman, the Bill currently leaves open, as does indeed the current legislation, whether the Chairman should also be the Chief Executive. Whilst there is no intention to the change the current arrangements whereby Howard Davies is the Chairman and Chief Executive and there is a non-executive Deputy Chairman, Ministers recognise that in the longer term there may be other arrangements which could work. They are however mindful of the fact that parallels with other models of corporate governance are not exact. For example, whereas the shareholders of companies are likely to be fairly diffuse, in the case of the FSA there is clear accountability to Government and Parliament, as well as to stakeholders more generally. There is also a good case for a strong line of direct accountability to Treasury Ministers from the senior executive of the regulator.

Chairman:  I think that takes us into the first set of questions in relation to the FSA Board that we want to put.

Mr Loughton

  344.  Could I start with the point about the joint roles of the Chairman and Chief Executive, as David Roe has just said. He has come up with the news there that in the longer term apparently Ministers acknowledge that other arrangements could work. Are you satisfied at the moment that the roles of Chairman and Chief Executive, however trustworthy and upstanding the particular character Howard Davies may be, is a workable concept? Would it be much more desirable that they are separated right from the outset?
  (Dr McDonald)  I will take that question. I think it is important to bear in mind that you are dealing with a public body where the focus of the Board is on fulfilling the objectives of the FSA, in other words it functions differently from the way in which a company board functions. I think that certainly in this interim period, where the amalgamation of the various SROs into one body has been a long and difficult process, and also where at the moment you have below the Chief Executive a triumvirate of senior managers. Probably it has been an efficient way of establishing a new regime and I think the Government is right to take that view on this interim period at least, maybe in the future there will be changes in the structure, indeed some changes in the structure of the FSA have already taken place over the past two years. As you are moving on to become a fully established board, a fully established regulatory authority, so the specific tasks that had to be completed in this two year period will fall away and the main focus will be on the conduct of regulations. I do not think it has presented any particular problems at present. It may be that one wants to look again at the structure in the future, one has to be flexible.

  345.  Yes. With respect to Dr McDonald the last time from classical history we had a triumvirate it resulted in an emperor emerging from it. Are you realistically suggesting that in a couple of years' time, the timescale you put forward, Howard Davies will be very happy to split his roles? Does not the character of having a joint Chairman and Chief Executive alter perhaps the views of the majority of non executive directors on the board whereby the person chairing that meeting, running an organisation, also sets the agenda and puts the points that he wants to discuss on the agenda. Do you not think it changes the whole character from the outset?
  (Dr McDonald)  I have to say that I have not noticed the difference in character which you suggest. The SIB Board, of course, and SIB itself was a much smaller organisation, that did have an Executive Chairman and Chief Executive as well who obviously had to agree on the agenda presented to the Board. Under Howard Davies, Howard Davies has to operate with the support of the senior managers to carry the business forward and establish fully the new regulatory authority under the new legislation. Whether or not it should take a different structure in the future is an open question one would have to concede.

  346.  We have had some other views, it is conscious that the view from Howard Davies and the FSA would be not one of timescale, this is the news that has come out now.
  (Dr McDonald)  No, I am not speaking for the FSA, these are my views entirely.

  347.  Indeed, but one of precedents, based on the Bank of England we are going to have a governor, rather than a chairman of the board or whatever. Is it justified to model the FSA on the Bank of England now or in two years or whenever?
  (Mr Telford)  I think our view is that it does not necessarily cause a problem having the two offices merged into one person, it could do. Of course if the suggestion was put forward that it could cause a problem, that is quite possible. If there is the flexibility to change that structure and to have a division between those two roles I think that is right. I think we see that at the moment there is a big job to do bringing together the different SROs, in setting up the new body and establishing perhaps a consistent theme to the FSA and what it does and that it may be appropriate to have that joint function at the moment. We would take very much the view that it is an evolutionary approach to regulation we have to have and things may look very different in six months never mind six years' time. If the person themselves is not satisfactory then they are accountable for what they are doing and could be replaced. We would not be wedded, I think, to saying that there must be a division over all time or one office for all time. It is reassuring that can change as and when it is necessary and that could be sooner or it could be later.
  (Ms Saunders)  I would just like to supplement that by saying personally I think that the Government is intending to establish a world class regulator which is recognised worldwide as being such. I think the most important thing, therefore, is that the standards that are set within the FSA are perceived externally by the public and those to whom the regulators are accountable as setting the highest possible standards of corporate governance. I think it is for others to judge whether the structure that is currently proposed stands up against those tests.

  348.  Do we know how they do it in other countries?
  (Ms Saunders)  I do not personally.

Chairman:  I think the majority have an executive chairman—that would be my observation.

Lord Haskel

  349.  It is all very well to have a paid chief executive as chairman when things are going well but of course it is when there is trouble you need a non-executive chairman or a separate person to raise matters on the agenda which maybe the chief executive would find it difficult to raise or would not want to raise. I wonder if you have any observations on that?
  (Dr McDonald)  I think in my experience there has from time to time been a creative tension, shall we say, between the chairman and the chief executive but that has been all to the good. You are talking about boards with a majority of non-executive directors whose function is to look at broadly speaking two issues, the way in which the authority is actually running itself and of course to focus to a large extent on policy issues which obviously are on the basis of papers put before the board but which require a detailed and thoughtful and open discussion by all members of the board. I think that although the model that people naturally look to nowadays is very appropriate in the case of a commercial company, I do think it is somewhat different and we can afford to be more flexible in the case of a regulatory authority. I do actually think it is not the most important issue to consider as regards the organisation running the regulatory authority.

Lord Poole

  350.  Perhaps we could ask what the most important issue is? You were talking about the structure and the organisation. What is more important?
  (Dr McDonald)  There are various important issues but let's focus on two because these two are the two that you are concerned with today. The nature of the board is extremely important; the individuals and the kind of contribution that they bring to the board and the way and extent to which they can help to shape and direct regulatory policy. I am setting aside just for the moment the issues of enforcement and accountability of that because we are focusing on a slightly different area. The second board issues are practitioner and consumer input and both are absolutely vital to the proper functioning of a regulatory authority. In some ways I take the view that, although of course there are often clashes at first, what one needs to do is bring the practitioner and the consumer interest together in such a way that the regulations that one proposes both protect the consumers and are conducive to the conduct of good business and best practice on the industry side. If we are looking at the general functioning of the authority, then the contribution that the board makes and the contribution of the practitioner and the consumer input is extremely important to the way in which a regulatory authority can function and to its effectiveness.

Lord Haskel

  351.  Coming back to the question of the board, it has been suggested that the appointments to the FSA board should be subject to confirmation by Parliament—a kind of confirmation hearing I suppose. Do you think this is important? What is your view about it?
  (Dr McDonald)  Now that we have got the Nolan procedures, we do have very important checks. Secondly, it is important that the process of selection of board members should, of course, be open and fair but also efficient and if we go too much down the American path we could find ourselves waiting for a very long time for members of boards to be appointed. I have on occasion visited some of the American regulatory authorities to find they are well short of a full complement of commissioners because Senate or Congress have not approved them and months and months have gone by, so hopefully we have hit upon a relatively efficient method of appointing persons to the board.

Mr Sheerman

  352.  Dr McDonald, in her opening statement, did conclude she wanted a strong united board. In some respects that is what some of our participants in these "seminars", as I think we like to call them, are worried about—a strong united board that is really too strong—and that the lines of responsibility run all the way to the FSA, which has a chairman/chief executive as we have just been discussing, whereas other voices have said the accountability should really run through Ministers to Parliament and that should be the route—whether it should be consumers, the protection panel or the Ombudsman. The Ombudsman only this morning was saying to some of us in the Committee that he would like to see that accountability to Parliament through Ministers, not to the FSA. Do our panel think that is an important principle?
  (Dr McDonald)  There are a couple of points that I would like to make here. When I was talking about a strong and united board, I had a couple of issues in mind. One is it seems to me that some of the questions pre-suppose that consumer "representatives"—which is not the term one should apply to membership of the board—and practitioners or people from practitioner background would be somehow opposed on the board. What one wants on the board is individuals who bring a variety of skills and expertise to the board. One should not split the board into too many sub-committees where sectional interest might develop, if I may put it like that. What I have found in my experience is that, particularly on regulatory policy issues and indeed on a range of issues, there is considerable constructive debate which then leads to a view which the chairman accepts or rejects (or wishes he had not but nevertheless accepts) so from that point of view, when you are talking about a strong board, you are looking at the board in relation to the chairman and the executives. Then, from the regulatory authority and from the board, one should be looking from the board through the chairman to the accountability to Parliament and to Ministers but what the chairman is bringing to the Treasury and to Ministers is, in fact, the concerted views of the board and that should be that kind of check and distillation of policy and decisions on other issues.
  (Ms Saunders)  To go back to the initial question which was the extent to which the FSA should be accountable to Parliament through ministers, in terms of the creative tensions that there are between the four statutory objectives that the FSA is going to fulfil, it is ultimately essential that there be accountability right back to Parliament. However, there are questions—and the discussion today begs them—about the extent to which that is carried through and the ways in which it can most effectively be carried through. The suggestion that one of the ways of delivering that accountability should be through the FSA's annual report and through interrogation of it—either by a scrutiny committee like this or by a Treasury select committee—are sound but in addition it is essential that the FSA be required to respond to the various statements that are made and challenges to the way in which it delivers its performance by both the consumer panel and the practitioner panel.

Lord Poole

  353.  I do not understand that. Could you expand, please?
  (Ms Saunders)  When the consumer panel makes recommendations to the board, whether through comments on consultative documents or policy statements, the FSA should be required to respond to those and, indeed, to account for its performance against its consumer protection and awareness objectives in its annual report. If it is dissenting from what the consumer panel is itself recommending, it should make clear why and the basis on which its regulatory judgments are made. I recognise that there will be times when there are balances to be struck but I think it is very important that the FSA board itself is clear about what balances have been struck and the basis on which those have been struck and, if there are trade-offs to be made, that it is prepared to be open about what those are. I would like to supplement this by commenting briefly on the question of consumer expertise within the board itself. There is no doubt that, with the size and scope of the FSA, it will be an executive regulator and the ability of any board to influence day-to-day operation is bound to be limited. It is very important for there to be a majority of public interest people on the board but in addition, if I draw from my experience as a PIA board member, it is extremely helpful to have several members of that board who have a background in consumer matters—consumer research, consumer understanding—so they bring to that board a recognition of the imbalance within the market place and in power within the regulatory structure itself. Certainly within the PIA board there have been three people coming from precisely that background on what is a very large board and we have, over a period of time, had an influence in the way in which the practitioners themselves approached the issues. However much it is desirable for there to be a unitary board—and without a unitary board regulation cannot function effectively—the fact is that, in the early stages at least, people come carrying their previous baggage and they have to learn to approach this broader set of objectives in a balanced way. From that point of view, if you have only got one potential person who understands the sort of approach a consumer expert can take and the sort of questions that those coming from an investor's perspective can raise, then they are very isolated.

Mrs Blackman

  354.  Clarifying what you said, you are supportive, then, of dedicated consumer expertise on the board?
  (Ms Saunders)  People should be appointed on the basis of Nolan principles and on the basis of their previous expertise. I am suggesting that one of the very important elements of expertise is understanding the consumer end of the market and I believe that to have one board member out of twelve or fifteen is simply not enough to deliver that.

  355.  So are you fully supportive of the Government's response on this issue at present?
  (Ms Saunders)  It seems to me that the Government's response does not go far enough in recognising that public interest is very broadly drawn and that there are people who have sets of principles based on their consumer understanding and market research techniques who can actually bring added value to a board and whose primary function is consumer and investor protection.
  (Mr Telford)  Certainly looking at a regulator who has statutory objectives to protect consumers and to deliver good consumer products in the market place and to look at a whole range of consumer issues then yes, while they must appoint competent people with good qualities and in a transparent way, they must give attention to the fact that consumer knowledge and the way the market works for the retail, high street consumer is just as important as it is to understand the way regulated firms operate and their priorities and the criteria they have when they look towards a regulator for success and for bringing something to the market place. Clearly the FSA board and the FSA must be accountable to Parliament absolutely. There must be a strong board. We would probably say more than a united board there must be a questioning board. The job for the board must be to question what the FSA as a body is doing; what policy initiatives it has; where its spending resource is. Part of that is to say to themselves and the FSA board "We must make it clear to our constituents"—whether that is consumers or regulated firms—"what we are doing and why", and if consultation responses or reports are put into them, or research, they must be in a position to respond and say whether they will do something and, if they will not, why not. They must be quite clear and open and that would inform everyone what the FSA is or is not doing and it would also help Parliament in scrutinising the board itself.

Chairman:  We must move on. We have two panels this afternoon and a busy agenda so we must move on to the questions of consumer and practitioner panels. A number of people made statements in their introductory remarks about how consumer and practitioner panels operate so let us move on to that.

Lord Montague of Oxford

  356.  Could we look for a moment at the interaction between the consumer panel, the FSA and the Ombudsman? I will just take you up for a second in that spirit about appointments to the FSA and this strong consumer experience on bodies to which you refer. I am a bit worried in hearing that that it might undermine the consumer panel. Is it not slightly fulfilling the role of the consumer panel and might not a better approach be to have some of the members of the consumer panel as members of the FSA? That is just a thought for you to comment on. Thinking of your role, however, and the interaction of the consumer panel and the FSA and the Ombudsman scheme, perhaps you could tell us how you anticipate that working. Do you, for example, expect the FSA to make a statement about consumers in this activity without reference to yourself?
  (Ms Saunders)  Can I take the second part first because it will be helpful? In terms of day-to-day operation, the consumer panel would be rightly irritated and feel that an opportunity had been missed if the FSA was making substantial public statements impacting on consumer protection and its attempts to fulfil that role without having had any reference to us. It would have lost an opportunity for consultation and to get support potentially for what it is doing or to consult us in advance on what it was doing. I would genuinely expect, however, that working relationships would be good enough that the FSA would bring such matters to us in advance and already, in terms of practice, we are being consulted in advance on preparations for consultative papers; we are having regular feedback into our meetings on the issues that the consumer relations division are dealing with and we have an opportunity to comment back to staff. Over time, if we build on the experience of the PIA consumer panel, which has been in existence for four years, then I would also expect us to call in FSA staff and discuss with them the issues, challenges and performance of their own duties. That is the only way in which we can get access to the intelligence of what is going on on the ground and feedback about the regulatory lessons that the FSA is learning in order to influence the development of our own policy. The fact of the matter is that it is through monitoring enforcement and surveillance of the market that the FSA will develop a lot of its intelligence. We have to counter that, however, by research of our own which enables us to compare what is actually happening on the ground in the consumer market and the experiences that individual consumers are having with what the FSA tells us it is doing. That is very important indeed. When it comes to the question of whether members of the consumer panel should be members of the FSA, I am not quite sure whether you mean members of the FSA staff or members of the board.

  357.  I meant members of the board.
  (Ms Saunders)  There have been very substantial discussions in the past about that. As chairman of the PIA consumer panel I was, and am, a PIA board member. It is recognised that having the chair of the consumer panel on the board implies a degree of compromise of independence and you can argue it both ways. There is a value in having separate people with consumer expertise on the board—although I have to say that that makes my relationship with the board as chairman of the FSA panel very important indeed because I have to be able to work with that board to influence the board and do so from the outside but, in terms of credibility of the panel as an independent voice, the separation is helpful.

  358.  Are you envisaging a relationship with the Ombudsman scheme and exchange of information?
  (Ms Saunders)  Yes. I would certainly expect the panel to receive information from the Ombudsman scheme on the progress of complaints, the volume of complaints and the issues arising out of complaints and we will seek that from the FSA Ombudsman bureau. I would very much hope the gateway to access information will not inhibit that relationship but obviously it is not yet established. It is very important.
  (Mr Telford)  May I say I would just agree with that. We certainly see a role, of course, for a very strong and independent consumer panel in terms of budget and research, acting very much as an advocate on consumer views—exclusively, you might say—as long as there is consumer involvement and a consumer voice on the board as well. We would not wish to see a model where the only consumer representation on the board was because the consumer panel person was brought on where that was seen as "Well, now we have done enough". We would see a role in both fields for consumer involvement.

  359.  In your opening statement, Ms Saunders, you talked—and I agree with you totally—about the importance of the one stop image (which I am sure is going to develop, and it is going to be a great disappointment to consumers if it does not prove to be a one stop) and you suggested pensions should come in and long term care, but you made no reference to a very delicate area as far as consumers are concerned—namely, consumer credit. Would you care to comment on that?
  (Ms Saunders)  The whole area of consumer credit is tied up with the OFT's existing responsibilities under the Consumer Credit Act and with the relationship between that Act and mortgage regulation. We are very strongly of the view that mortgage regulation should be within the scope of the FSA and we will contribute evidence to the Treasury as part of its review. When you then get into the wider area of whether all loans should be subject to FSA jurisdiction, that has not been looked at across the piece and a review of that would need to take place. It is very important for the longer term credibility of the FSA that, when consumers access its helpline or want to access the Ombudsman Bureau, they do not get responses which keep saying "We are the Financial Services Authority but we cannot deal with that".

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