Georgia Gould
MP for Queen's Park and Maida Vale · Labour · United Kingdom
“The Children’s Wellbeing and Schools Act also replaces sections 10 and 11 and of the Education and Inspections Act with an amended section 10.”
“The current system means that there are real geographical discrepancies, and sometimes there is not a trust available to set something up quickly, so we want local authorities to have the flexibility to respond quickly to demands and to offer that provision where it is needed. The hon.”
“I thank Members for the range of important questions, although I think they are broader than the individual draft regulations we are discussing today. I will start with the question about special places in specialist schools and how we can ensure that there is consistency.”
“We want to have really strong standards and consistency in critically important areas. We know some of the real challenges that young people face in misinformation and the need for digital literacy in a changing world.”
“The statutory instrument makes consequential amendments arising from those provisions. The amendments, which are to both primary and secondary legislation, are necessary to ensure that references to the legislative framework for opening new schools are correct and consistent across the statute book, and to update provisions to ensure that…”
“Currently, where a new maintained school replaces an independent school, a teacher of the independent school transferring under transfer of undertakings legislation to the new school may choose to retain their existing terms and conditions or choose to opt in to the schoolteachers’ pay and conditions document.”
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“A regular deduction may specify different amounts or different methods to be deducted at different times. For example, the first deducted amount may be higher than the following payments to recover the debt in the most efficient way possible. Deductions may not be made until 28 days after an order has been made. That provides a safeguard for the liable person, allowing them the requisite time and opportunity to request a review under clause 45. Banks must comply with the direct deduction order, whether regular or lump sum, to ensure adherence to these measures. A penalty may be imposed for failure to comply under clause 53. Clauses 22 and 23 send a strong message to those with fraud and error-related debt to the Government, while preventing hardship and protecting those who are vulnerable.”
“The challenge was to balance that with the need to send a strong deterrent message to those who have the means to pay their fraud and error-related debt to Government, but refuse to do so. Clause 22 caters for that by ensuring that the terms of the order will not cause the liable person, any other account holder, or a person living with or financially dependent on the liable person or any other account holder, hardship in meeting essential living expenses. To ensure we include other considerations outside of this list, the terms of the order are also required to be otherwise fair in all circumstances. Clause 23 provides the contents and effect of direct deduction orders. Regular and lump sum direct deduction orders must specify the amount, or a method for calculating the amounts, to be deducted and when.”
“A too-high regular deduction would disincentivise earnings so strongly that it would result in slower, not faster, recovery of funds for our public services. I turn to clause 22, which sets out the amount of deductions that there may be under an order. We have ensured that the amount of debt we collect at any given time is fair. That is why we established maximum limits based on whether debt was accrued due to fraud or error. We have discussed the safeguards and precedent at length, and the powers here build on precedent across Government. A key consideration throughout the creation of the debt measures was to robustly prevent hardship, learning from best practice.”
“However, the lump sum deduction must still adhere to the core principles, in meeting essential living expenses and be otherwise fair. That ensures that where a higher proportion of the payable amount is present in the account, we can recover the debt more efficiently while maintaining those key safeguards. We are also able to issue a lump sum direct deduction order and then establish a regular direct deduction order. That allows us to take an initial higher amount of deduction, with regular payments thereafter where appropriate. This is a better route than allowing for a higher level of deductions. It builds on established practice, is proportionate while still being impactful, and it limits the disincentive to earn that an unlimited regular deduction would create.”
“First, I want to make absolutely clear that I was not accusing the hon. Member of any fraud, but just using a hypothetical. In that instance, the PSFA would use the lump sum direct deduction orders, so they would be able to take the full amount. They would not need to use the direct earnings attachment. It would be a lump sum direct deduction order that would recover that money. As I said, there are no limits to that, except that it does not cause hardship in meeting essential living expenses. I hope that provides some reassurance. The 40% maximum limit is in line with existing legislation. The amendment seeks to remove the 40% cap for fraud, allowing a higher percentage of regular deductions to be made. To be absolutely clear, for lump sum direct deduction orders, there is no maximum limit on the total amount of deductions.”
“As I have outlined, that is why we met with key representatives of the finance industry, including UK Finance, individual banks, building societies and the Financial Conduct Authority, to ensure that there is close and sustained engagement on this Bill. We heard directly from UK Finance in evidence last Tuesday. The finance sector has supported the Bill’s objectives and there are constructive conversations already taking place. The direct deduction order powers in this Bill align with those existing powers and we will continue working with the DWP to align direct deduction order processes across both Departments where possible to simplify implementation.”
“That will ensure that the direct deduction order and deduction of the bank’s administrative costs do not cause the liable person, other account holders, those living with the liable person or joint account holder or those financially dependent on the liable person or joint account holder hardship in meeting essential living expenses and that the deductions are otherwise fair in all circumstances. Regarding the burdens on the financial services sector, the Government are extremely mindful of the burdens that the Bill places on industry, including financial institutions. We want to ensure that banks are not subjected to disproportionate burdens or costs in complying with these measures.”
“That power will be used to introduce a cap on the charges which can be imposed under this clause and which can be adjusted in line with inflation and to ensure that the charges remain reasonable at all times. The amount may be deducted by the bank immediately prior to the direct deduction order. To safeguard against that causing unintended hardship, the question of deducting the bank’s administrative costs for the liable person must be taken into account when complying with the hardship considerations outlined in clause 22.”
“Clause 24 enables a bank to deduct administrative costs that it has reasonably incurred when complying with a direct deduction order from the liable person’s account. This provision is essential to ensure that banks are adequately compensated for the administrative efforts required to comply with the orders, thereby facilitating the efficient operation of debt recovery processes while protecting account holders from undue financial strain. A direct deduction order will then specify how the bank can deduct its administrative costs while complying with the maximum amount of total deductions as specified in the clause 22. Clause 37 contains a power to make further provision through regulations as to the administrative charges which can be imposed by the banks.”
“Clause 24 accordingly ordered to stand part of the Bill . Clause 25 Insufficient funds Question proposed, That the clause stand part of the Bill.”
“We are committed to continuing engagement and consultation with the financial services sector through the passage of the Bill and its implementation —indeed, that has been ongoing since evidence was given last week. It is important to put the cost to banks in the context of the amount that will be recovered under the Bill, which we estimate to be £940 million—money that is vital to delivering public services. It is right that every part of the system plays its part in recovering money that was lost to fraud. Having outlined the key provisions in the clause, I urge the Committee to agree that it should stand part of the Bill. I have just received a message: I thought I said that DWP would produce an impact assessment in 12 months, but I said three months. I assure everyone that it is 12 months. Question put and agreed to .”
“Equally, we believe that the purpose of amendment 23 is already provided for through the regulation-making powers under clause 37. As I stated, we have consulted and will continue to consult the banks to implement the measures in part 1 of the Bill, as set out in the published impact assessment. In part 1, the costs to banks are expected to be minimal and offset by the ability of banks to recover administrative costs from the liable person. Clause 24 enables the banks to recover administrative costs from the liable person, and clause 37 provides for regulations to be made in relation to the costs that a bank may recover by virtue of clause 24. We intend the regulations to be reasonable for those paying and for the banks. Before introducing such regulations, a consultation must occur with those representing the interests of banks.”
“We have already published the Bill’s impact assessment, which sets out the minimal expected cost to businesses of its measures, where it has been possible to do so, including to banks. The impact assessment has been green-rated by the Regulatory Policy Committee. DWP has also committed to providing estimates in a subsequent impact assessment of the business costs for DWP’s eligibility verification measure, within three months of Royal Assent. So DWP has already come forward to commit to bringing forward that information as part of the package. I am confident that that will provide the necessary transparency that the shadow Minister seeks, and I hope that our commitment again today to provide those costs reassures hon. Members.”
“There are further protections in the Bill. Clause 37 contains the powers to make further provisions through regulations on the administrative charges that can be imposed by the bank. The powers will be used to introduce a cap on the charges that can be imposed under the clause and adjusted in line with inflation. To give further reassurance to the Committee, this is in line with the powers that HMRC has through the Enforcement by Deduction from Accounts (Imposition of Charges by Deposit-takers) Regulations 2016. For HMRC, the regulations specify that the amount should be “the lesser of…the amount of those administrative costs reasonably incurred by the” bank “and £55.” So there is precedent, and the necessary regulations will be made in due course. In my view, new clause 6 is not required.”
“I referred in my opening remarks to the positive and ongoing conversations that we are having with banks and the UK finance industry, and that was reflected in the evidence we heard. A UK Finance representative said that a number of conversations with industry have taken place since the measures were announced, and referred to “constructive conversations”. Concerns were raised about safeguards for the charges that banks could put in place under the PSFA measures, and I have already outlined some of the safeguards in place. The deduction of a bank’s administrative costs should not cause the liable person, other account holders, those living with the liable person or joint account holder, or those financially dependent on the liable person or joint account holder hardship in meeting essential living expenses, and they should be fair.”
“The clause sets out the action to be taken if the amount in the account is lower than the amount specified in the direct deduction order. Should that situation arise in relation to a lump sum direct deduction order, no deduction is to be made by the bank, and the bank must notify us as soon as possible. If it occurs in relation to a regular deduction order, the order is to be read as requiring the deduction to be made on the same day the following week. If the amount in the account still remains lower, no deduction is to be made and the bank must notify us as soon as possible. That approach ensures that individuals are not unduly penalised or driven into financial hardship because of insufficient funds, while maintaining the integrity of the debt recovery process through prompt communication and reassessment.”
“There are a number of options to ensure the full recovery of defrauded money to the state. Question put and agreed to. Clause 25 accordingly ordered to stand part of the Bill. Clause 26 Restrictions on accounts: banks Question proposed, That the clause stand part of the Bill.”
“I am grateful for the shadow Minister’s questions. This clause and his questions really highlight the balance between safeguarding vulnerability—ensuring that people are not left without money to be able to support themselves and dependants—and recovering all the money owed to the Government. Hopefully, the shadow Minister will be reassured that alternative recovery methods will be available, including using other powers in the Bill to gather information on, or recover money from, other accounts held by that liable person. If an individual continues to try to frustrate the process, as the shadow Minister has described, there are civil penalties through deduction orders of £300. If all the powers in the Bill are frustrated, the authorised officers will be able to apply to the courts to seize assets and to use other powers available.”
“They are also balanced within the wider direct deduction order measure, which includes review and appeal rights that are also intended to be subject to independent oversight, to be discussed later. Should a person frustrate the effect of the first order or direct deduction notice, a trained authorised officer may decide to impose a penalty under clause 53.”
“To clarify, frustrating the effect of the first order in this context means frustrating the effect of the proposed direct deduction order, the terms of which are set out in the first notice. Frustrating the effect of the first notice or the final direct deduction order might include a liable person creating a new bank account in order to redirect the payment of their salary, or the liable person falsifying the extent of their protected essential living expenses. These restrictions are vital to ensure that funds necessary for debt recovery are not deliberately concealed or moved, thereby upholding the fairness and integrity of the public fund recovery system.”
“The bank must ensure that no transaction occurs that would result in the hold account’s balance falling below the amount transferred into it. When a bank transfers an amount into a hold account, it must ensure that in doing so, it does not cause any disadvantage to the liable person or any account holder. These provisions are essential and are a key safeguard to ensure that funds required for recovery are preserved while also protecting account holders from any disadvantage, thereby maintaining trust and fairness in the enforcement process. Clause 27 imposes restrictions on account holders to prevent them from taking any action that may frustrate the effect of the first notice or direct deduction order, which the shadow Minister raised concerns about.”
“Direct deduction orders will be an effective tool in recovering money owed to the public sector. However, it is important that we include measures in the Bill to make clear the obligations of banks and account holders with regard to the orders. Clause 26 introduces restrictions on accounts from the perspective of banks. The bank must ensure that the account is not closed at the request of the account holder. If the notices relates to a lump sum direct deduction order, the bank must also secure that no transactions occur that would reduce the balance below the amount specified on the order, or the bank may transfer the specified amount, or the amount in the account if it is lower, into a hold account created by the bank to protect it.”
“The measures have been carefully thought through, and they include safeguards for vulnerability but also the ability to step in if people are deliberately frustrating the process. We will issue guidance to banks on how the three months of bank statements will be determined, and authorised officers will work with banks to ensure that this works effectively. The shadow Minister asked about the penalty. It will be a £300 fixed penalty notice for failing to comply. As with every part of this, people will be able to request a review and, ultimately, to appeal. Question put and agreed to. Clause 26 accordingly ordered to stand part of the Bill. Clause 27 ordered to stand part of the Bill. Ordered, That further consideration be now adjourned. — (Gerald Jones.)”
“It is important to set out again that these powers will be used in the last instance and, in many cases we hope they will be a deterrent. In the majority of cases, we expect people to engage with the authorised officers and come to a voluntary agreement. If people do not agree, the powers will be used only after an application to a court to determine the ability to recover that debt. In the first instance, we expect these powers to be used in a very limited fashion; the impact assessment talks about fewer than 10 cases a year. There is ample time to work through with banks how these powers are used and ensure that it is proportionate. The shadow Minister raised concerns that the powers are too harsh in some cases and that they will leave people vulnerable in others, which shows the balance involved.”
“Establishing clear, responsive and fit-for-purpose processes supports that approach, ensuring that the debt recovery mechanism is future-proofed and that the debt recovery process remains responsive and fair. Having outlined the key provisions in clauses 28 to 33, I commend them to the Committee.”
“In all cases where a deduction order is altered or proposed to be so, the liable person, any joint account holders and the relevant bank will be notified. These clear communication requirements safeguard the interests of all account holders involved. Collectively, the clauses outline clear and transparent processes so that the liable person, any joint account holders and the banks carrying out such orders understand how they can be varied, suspended or revoked. They enable necessary flexibility in the debt recovery process so that the orders reflect the changing circumstances and financial realities of those affected, thereby ensuring fair and appropriate payments. It is important that we maintain integrity and fairness in our approach to debt recovery and allow for review and appeals.”
“However, it is also essential in ensuring that decisions regarding variations or revocations of direct deduction orders are based on the most current and comprehensive financial information, thus safeguarding both the Government’s recovery efforts and ensuring that the amount of deductions remains proportionate and fair. Clause 32 defines the circumstances under which the operation of direct deduction orders is suspended. A regular direct deduction order may be suspended and restarted at any time. Clause 33 sets out what happens in the unfortunate circumstance that a liable person dies during the period of a direct deduction order. Should such a circumstance arise, a bank will cease to be subject to a direct deduction order on becoming aware of the liable person’s death.”
“Clause 31 concerns further information notices that can be given to the bank to determine whether to revoke or vary a direct deduction order. If the further information notice concerns a joint account, each account holder other than the liable person must be made aware that the notice will be given and of its effect. That must be done before giving the notice to the bank. A further information notice requires the bank to provide statements of the account held by the liable person for the three months prior to the notice being given or a longer period as may be specified in the notice. The information given may also be used for the purposes of exercising the core functions only as outlined in clause 1. That is a key safeguard in the Bill to limit the circumstances in which the information given can then be used.”
“The order can also be varied so that it applies to another account held by the liable person, including an account with a different bank, if the variation is requested by the liable person and, if applicable, other account holders consent. The clause outlines the process for when a direct deduction order is varied to apply to an account administered by a different bank or to apply to a joint account. Clause 30 provides the authority to revoke a direct deduction order. There are some circumstances in which an order can be revoked, but the two circumstances in which it must be are when the payable amount has been recovered or when the liable person has sadly died. The order must be revoked as soon as is reasonably practicable after becoming aware of such circumstances.”
“That relates to some of the important conversations we had this morning about safeguards. If the application to vary the direct deduction order is in relation to a joint account, other joint account holders must be given an opportunity to make representations. Clause 29 allows a direct deduction order to be varied on application by an account holder or at the proposal of our trained authorised officers. That will be achieved by providing a revised version of the order to the liable person and any other account holders, giving them an opportunity to make representations about the proposed variation. The varied order takes effect when it is given to the bank or, if later, in accordance with the terms of the order as varied.”
“It is a pleasure to serve under your chairship, Sir Desmond. I look forward to another constructive afternoon of discussion. Clauses 28 to 33 set out clear processes for the variation, suspension and revocation of direct deduction orders. They mirror approaches already used across government for comparable powers and ensure alignment with standard debt recovery practices used by Government Departments such as the Department for Work and Pensions. Clause 28 outlines that any holder of an account subject to a direct deduction order can apply to vary the direct deduction order during its lifetime. This key safeguard protects the liable person and joint account holders by giving them the opportunity to be notified of any changes in circumstances at any time since the initial order was made.”
“If that is the case, it will then be possible to grow the operation of the team and increase the resourcing, but we are confident that the resourcing to deliver what is in the impact assessment and in the Bill already exists. Question put and agreed to. Clause 28 accordingly ordered to stand part of the Bill. Clauses 29 to 33 ordered to stand part of the Bill. Clause 34 Reviews”
“It is possible that payments might be suspended as part of that appeals process, but critically, in changing and varying the order, a person will be informed of that and they can appeal the variation—the amount and the existence of the order will have already been set through a court process. The impact assessment goes through PSFA resourcing. As I have said, the savings are modest, and we have deliberately kept them modest because of the resourcing available to the team and the officers who are in place. There is resourcing to carry out 40 cases a year under the powers, and that is the expectation. These are new powers for the wider public sector. We hope that they will be effective, generate more income and recover fraud, and there is a strong evidence base for that as these powers are used elsewhere.”
“Such circumstances might involve somebody being hospitalised and the orders needing to be stopped and restarted, or somebody agreeing to move to a voluntary repayment. Indeed, as the shadow Minister mentioned, they might bring forward information about their financial circumstances. As for going back to ask for further information from the banks, somebody might set out information about their vulnerability, financial circumstances or living standards, and there might be a need to check that with the bank—“The circumstances have changed, so we need to get more information from the banks.” So there is a provision to continue to gather that information. We will go through the appeals process on later clauses.”
“Critically, on any of these measures, it will be possible to appeal to the first-tier tribunal, so an independent appeal route is built into the system. We do not think that there needs to be a separate independent route, but it is important to come back to the fact that this entire system will be overseen in two ways. First, that will be done by a team outside the PSFA, working with an independent chair who will review the use of all of these powers. Secondly, as we have said, there is provision in the Bill for independent scrutiny, which we expect to be delivered by His Majesty’s inspectorate of constabulary and fire and rescue services. The ability to suspend and restart direct deduction orders gives flexibility to the authorised officers who lead the cases.”
“I thank the hon. Gentleman for the range of questions, which give me the opportunity to clarify a number of points. First, what happens if a liable person sadly passes away before paying the specified amount? The PSFA will still seek to recover the money owed to the state through the people acting on the estate’s behalf, and it will be recovered using the normal processes. Although there are not specific measures in this Bill, the PSFA will be able to use other existing debt recovery measures. As for the decisions being made, who will be making them and the capacity of the Minister, as I set out, the decisions will be made by authorised officers under the Carltona principle, and the review will be done by a more senior officer than the officer making the original decision.”
“I beg to move amendment 2, in clause 34, page 20, line 30, leave out from “review” to end of line 35. This amendment leaves out provision that is not needed; clause 29(5), (6) and (8) makes the necessary provision.”
“This provision is not needed because the requirements to give the varied order to the bank, the liable person and other account holders are already provided for in clause 29(5), (6) and (8). This amendment seeks to simplify the drafting and provide clarity, while not amending or removing any policy process or safeguards.”
“The reviewing officer will be a trained authorised officer of a higher grade than the original decision maker. They may decide to uphold, vary or revoke the direct deduction order. That decision will be based on an assessment of the material held and any relevant new information provided by the liable person. If a liable person disagrees with their decision, there are further appeal rights, which we will come on to shortly. Government amendment 2 seeks to remove a provision in clause 34(7)(b), which states that if a direct deduction order is varied, the varied order must be given to the bank and a copy provided to the liable person and other account holders.”
“The clause establishes the process to request an internal review of decisions made by authorised officers on direct deduction orders. The liable person or other account holders, in the case of a joint account, will have 28 days from being notified of an order, or a decision pertaining to a request to vary an order, to request a review. They cannot use the internal review to challenge the amount owed, as I just set out; that will already have been settled. Instead, this review can be used to challenge, for instance, whether a direct deduction order is the most appropriate form of repayment, or whether the deduction amount is fair and affordable. Internal reviews are important as they provide a straightforward and affordable way for the liable person to present a challenge to direct deduction order decision making.”
“I think that answers your question. In terms of the 28-day limit, it is important to remember that the money we are seeking to recover is from people who have been proved to have defrauded the state. It is really important that we get that money back, but I am happy to look at whether there is flexibility and to keep that under review. I think those were the main questions you asked.”
“I thank the shadow Minister for those questions. The circumstances in which someone might request a review include the ones that you set out. Primarily, it will be around affordability. There are clear provisions in the Bill on affordability and living expenses for individuals and their dependants. In terms of why the review by an internal officer can only focus on variation, it is important to remember that in these circumstances, a court will have determined the amount owed—there will already have been an independent process that has determined that. This is about the affordability of those payments. There might be other debts, and there are established processes to deal with that. If people are unhappy with the internal review, they can still appeal to the first-tier tribunal, which has wider powers to vary than the initial review.”
“Sorry—I think those are the main questions the shadow Minister asked. Amendment 2 agreed to. Clause 34, as amended, ordered to stand part of the Bill. Clause 35 Appeals Question proposed, That the clause stand part of the Bill.”
“The tribunal judge may decide to uphold the appeal and vary or revoke the direct deduction order accordingly. They could also decide to throw out the appeal. We are developing strong, effective oversight of all our measures in the Bill. It is important that there is the opportunity for independent tribunal oversight of these powers. Tribunals provide accessible justice and will be able to provide additional review where necessary. Ultimately, this is about being fair to the taxpayer, ensuring that money lost to fraud and error is returned, but it is also about being fair to those who have received that money and ensuring that proper and due process is followed throughout.”
“Clause 35 establishes the process to lodge an appeal of review decisions around direct deduction orders. Appeals will be heard at the first-tier tribunal. Appeals can be lodged only following an internal review by an authorised officer of a higher grade than the original decision maker. The liable person, or other account holders in the case of a joint account—the shadow Minister asked about that, and it is important to clarify that a joint account holder can also request a review and an appeal—will have 28 days from being notified of an internal review decision to lodge an appeal. They cannot use the appeal to challenge the amount owed; that will already have been settled by agreement or in court or tribunal proceedings. During an appeal, the tribunal may instruct the bank to pause the effect of a direct deduction order.”
“On the wider point about exceptional circumstances, the important thing about these powers is that they will be exercised by authorised officers, highly trained in investigation and debt recovery, who will have due regard to the best practice on debt within Government and the wider system and will take a case-by-case approach to individual circumstances and respond to exceptional circumstances. That is why we have multiple and independent points of review. Again, I have referred repeatedly to the independent oversight that will look at all those processes and report into Parliament. Question put and agreed to. Clause 35 accordingly ordered to stand part of the Bill. Clause 36 Meaning of “bank” etc Question proposed, That the clause stand part of the Bill.”
“We think the powers will be particularly focused on high-value and severe cases of fraud, and the team will work to ensure that we prioritise those cases. This feels like a proportionate use of resources, and we have consulted the Ministry of Justice, which has agreed that the first-tier tribunal is the most appropriate forum to hear DDO appeals. On the 28-day point, I said in my previous answer that we want to recover fraud as quickly as possible and are keen to not have undue delays, but the points about exceptional circumstances are well made. I appreciate the questions and I am happy to take them away and ensure that there is appropriate flexibility.”
“We expect cases to be resolved successfully by teams that are well trained, have all the information available to them and can take a case-by-case approach that is fair and proportionate, but in the event that an individual is unhappy with the outcome of the initial review, they can appeal to the tribunal. We expect the initial impact to be very small: our expectation is that we will be dealing with four DDOs, so even if they all go to tribunal, it is a small number, and this is an established process. We have deliberately chosen the first-tier tribunal because it is the most accessible and fastest part of the justice system. We hope that these powers are successful and can be grown, and I think we will learn a lot from the first phase of working in this way.”
“I thank the Committee for the range of questions and the opportunity to provide clarification. The decision on the set-up of the system was made on the basis of existing best practice in Government, particularly in His Majesty’s Revenue and Customs, so there is precedent for its working. The intention of the PSFA is to recover debt as quickly as possible, but in a way that is proportionate and does not leave anyone in financial hardship. If an individual applies to vary the amount they are paying back, the internal review and the more senior officer will look to resolve that matter in a proportionate way, and to avoid things needing to go to a tribunal. However, it is important to have independent safeguards in place.”
“Clause 36 establishes a number of definitions for terms used in the direct deduction order section, including the meaning of “bank” as a person who is authorised to accept deposits or to issue electronic money. This definition is supported by reference to appropriate legislation and regulation. The clause confirms that references to amounts in accounts must be in credit, thus ensuring that we do not push people into overdrafts. It also sets out how a person can hold an account by having their name to it, either solely, jointly or as a signatory. It is important that we have clear, agreed definitions for such terms, to aid the operationalisation of these powers and to prevent unwarranted challenges, such as whether a financial institution is in scope of the Bill.”