I was asked a question yesterday. It was asked by someone reading this blog, someone who I admire for her efforts at helping other people, and establishing a forum where ordinary people can share experiences and knowledge to help each other.
She asked me whether I would be submitting evidence to a current consultation being carried out by HM Treasury. This one. A new approach to financial regulation - Judgement, focus and stability. (Warning - it is 76 pages long, very detailed, and asks loads and loads of questions)
My answer? Very political - it was yes and no. You see for me I would like answers to simpler questions.
I think it was Robert Peston from the BBC who said that some of our larger Banks have a turnover far in excess of the whole economy of the UK. So why is it that - when I am only half awake, not yet had my first strong black coffee, - when my wife suddenly announces that we need milk for everyone's breakfast, - and that we have run out of toilet rolls - I arrive at the ATM to be told there are no bank notes available? Where is the consultation on that?
We are in many ways beseiged by consultations - all trying to find answers to very big questions:
How about this one? A call for evidence from BIS - Department for Business, Innovation and Skills - Consumer Rights Directive : Allowing Contingent or Ancillary Charges to be Assessed for Unfairness.
It's all about Bank charges, and it relates to the Supreme Court decision against the OFT - but does it deal with why there are no £10.00 notes in the ATM? Bet your life it doesn't! Nor does it answer my question to Lord Turner and the FSA - do you believe that the charges levied by Banks on their customers were and are fair or unfair?
Nor will you find an answer to my family's urgent need for milk and toilet rolls, nor my question to Lord Turner in this current consultation. It comes from the Independent Commission on Banking - Issues Paper - Call for Evidence. I misread that title at first, thought it said "Tissues Paper" - and thought yay, there is a Consultation that might give me an answer I need after all.
But no, that last consultation looks at some very big issues. You will hear those issues discussed often, Banks that are "too big to fail", should Banks be broken up - splitting the Investment banking from the Retail side of Banks, Narrow Banking, Utility Banks, etc etc.
Now, if unlike me and I believe most ordinary people, you need the day to day, minute by minute, services of a Global Investment Bank, and are not faced with the rather more simple problem of why there are no £10.00 notes in an ATM, or an answer about the fairness of Bank charges, then by all means please read every detail of those consultations.
But for me, and millions of ordinary people in the UK, right here, right now, I would just like Lord Turner and the FSA to answer my very simple question - do you believe that the charges levied by Banks on their customers were and are fair or unfair?
I now face a problem - I want you to keep reading this blog, but before I get to Test 3 and Test 4, I need to finish Test 2.
Perhaps your interest is waning somewhat - understandable. Why don't I just get to the point? Fair question. I could assure you that what I have to say is relevant, interesting, a "must read" - and yes, I do assure you it is all of those, but I am not sure that is sufficient to keep you here.
You like me, probably just want the answer to my question of Lord Turner and the FSA. Well, may I tell you once we get through Test 2, and Test 3 - you will get that very answer, because strangely it already exists.
The FSA have already given their answer - but we need to finish Test 2 and Test 3, and use the evidence that they will contain to show not just that it has indeed happened - but as importantly how it has already happened.
You see, I am not sure that Lord Turner or the FSA are even aware as I write that they regard the charges levied by Banks on their customers were and are unfair - yep, unfair, I will highlight and repeat that word just in case you missed it.
It will be evidence from within the very heart of the FSA that I will present in Test 4 that shows how they reached that conclusion.
Now, I already hear you asking - how could that be? How could it be that while the OFT took on three high profile Court appearances, and spent loads of your money and mine, lost, and then gave up, with no answer for anyone - how could it be that the FSA, our prime financial Regulator already knew and had the answer - at no cost to anyone? They just had to tell us, and instruct the Banks under the statutory powers they had - and insist that the Banks "treated customers fairly" - their highest level principle - how indeed could that be?
Ever watched Derren Brown, or indeed any magician? My absolute favourites are Penn and Teller - edgy! Well, all magicians use something called "misdirection". They manage to draw your attention away from what you should be looking at, and towards what they want you to see. That is what has happened over the issues of Bank charges. Everyone, and I do mean everyone that I have read or talked to, has been looking at the OFT and what they were doing, and nobody that I can trace, anywhere, has been looking at the FSA. Misdirection? I think so.
I will deal with closing Test 2 as quickly and as briefly as I can, and move through Test 3 again in as fast a time as I can manage - and as I do so I want you to remember that one word "misdirection", because it forms a major clue, not only over the issue of Bank charges, but also into the murkier world of the whole financial crisis - people looking in the wrong places, and not looking where they should have been looking.
Soon we will reach the final Test - Test 4.
Test 4 - Evidence, which must be irrefutable and unequivocal, that the Financial Services Authority expect charges to be a fair reflection of the additional administration costs faced, not a way to increase profits or offset costs from other parts of a business.
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