Examination of Witnesses

Part of Financial Services Bill – in a Public Bill Committee at 3:11 pm on 19th November 2020.

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Jesse Griffiths:

Absolutely; I agree. On consumers, to bring this back to high-cost credit—this links to the point about the purpose of regulation—regulators should always have at the front of their mind the impact on the most vulnerable people in society, and those who are in many ways excluded by the financial system. This is not just about consumers as a whole, although they are important; it should be about those consumers who will lose most if their needs are not taken into account.

One example that we have been discussing are the new regulations on open banking and open finance, which can lead to further exclusion of marginalised people, who might get their income, withdraw it as cash, and operate in the cash economy, or who often—this has been raised—get income from a lot of different sources, and in such small amounts that it is not recognised as income by the open banking system, as it is set up. Those are just small examples, but if the regulator is not thinking, “What is the impact on these people?”, they get missed. Unfortunately, in that example, it feels a bit like that discussion has been, “Well, if it works for 95% of consumers, then it is good.” If it does not work for 5%, that is probably the biggest impact that we should care about.