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Consumer Credit Bill

My Lords, the noble Lord is right to withdraw the second part of the amendment because it is unnecessary. I wish that he had withdrawn the first part for being inappropriate. The OFT is a non-ministerial government department. It has existed for more than 30 years. Its governance, including its accountability and responsibilities, was set out fairly recently in the Enterprise Act 2002, as the Minister explained this evening in relation to another amendment. It is not just that the independence of the OFT would be affected adversely by this amendment; I suggest to the DTI, which as the most closely related ministry is the ministry you would expect to offer comments, that the OFT’s guidance emerges out of its experience over the years, especially on licensing, creditors, their problems and malpractices and so on. The DTI will have less to do with that now because, as noble Lords have noticed, appeals against OFT decisions on licensing, which used to go to the DTI, will under this Bill go to the consumer credit appeals tribunal. Without being rude to the DTI, especially with my noble friend the Minister in his place, I wonder whether it would add value to the work of the OFT in issuing guidance, because it does not have, and will in future have less, day-to-day case law experience of relationships between the licensor and the creditors.