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House of Lords Hansard
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Cash Ratio Deposits (Value Bands and Ratios) Order 2018
16 May 2018
Volume 791

Considered in Grand Committee

Moved by

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That the Grand Committee do consider the Cash Ratio Deposits (Value Bands and Ratios) Order 2018.

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My Lords, I beg to move that the Committee has considered the draft Cash Ratio Deposits (Value Bands and Ratios) Order 2018, which was laid before the House on 16 April this year. The draft order makes changes to the cash ratio deposits scheme, which is the way by which the Bank of England funds certain functions. Under the Bank of England Act 1998, banks and building societies of a certain size are required to place a proportion of eligible deposits in an account with the Bank of England. In turn, the Bank invests these deposits in interest-bearing assets, namely, gilts. The return on those investments is channelled into the funding of the Bank’s monetary policy and financial stability functions. There is a resultant systemic benefit to the whole banking sector from the sustained and stable operation of these functions, as well as for the wider public. For these reasons, the Government are confident that the cash ratio deposits scheme is and remains the most appropriate means of funding the Bank’s important policy work.

The operation of the scheme means that the Bank’s income generated by the scheme is driven by two factors: first, the yield on gilts; and secondly, the size of deposits eligible for the scheme, which is largely driven by the overall performance of the banking sector. Over the last five-year period, gilt yields and to a lesser extent the growth in deposits have been lower than expected. On average, annual yields were 2.7% versus the 3% expected in 2013. This has caused income to be £70 million lower than was forecast at the last review. A similar shortfall arose in the five-year period leading up to the last review of the scheme that was carried out by the Government in 2013. The Government are seeking to address this problem by recalibrating the parameters of the scheme over the forthcoming review period.

In particular, the Government are seeking to move from a scheme that currently uses a fixed ratio as the measure by which institutions calculate the proportion of their deposits to be placed at the Bank and will instead move to one where the ratio will be indexed to actual gilt yields. Under an indexation approach, the ratio will be calculated once every six months to align closely with prevailing gilt yields. Such an approach should lead to a smoother income profile for the Bank as it will dynamically adjust to the investment environment. It will reduce the risk of a shortfall in income if yields do not perform as expected and reduce the likelihood of future funding deficits for the Bank. The indexation model also has potential benefits to payers themselves. For example, if gilt yields were to increase, institutions would not then be required to place as much on deposit at the Bank.

The Government have consulted on the changes to the parameters of the scheme before us and the majority of respondents have acknowledged and accepted the increased costs associated with the Bank’s functions. Alongside the Bank’s efficiency savings, the changes proposed by the order will ensure that the income generated by the scheme covers the costs of the Bank’s policy functions over the next five years. As the Bank’s costs have increased since Parliament last agreed to this scheme, it has committed to maintaining its costs at 2018-19 levels over the next five years and that any subsequent enhancements will be funded from efficiency savings generated elsewhere. These cost-saving measures include a comprehensive programme of cost-containment and reprioritisation. The Bank will also continue to increase transparency around its income sources and the use of income generated under the scheme.

The proposed changes to the cash ratio deposit scheme are expected to increase the Bank’s income over the next five years and generate income that is closely aligned to the Bank’s forecast costs. It is worth noting that the amount that most institutions are required to deposit at the Bank under the scheme is relatively small. In December 2017, 81% of deposits made were by just 20 institutions, with 14 of those contributing more than £50 million. The majority of the contributions are sourced from larger banks and building societies.

The Bank of England Act 1998 sets out that the cash ratio deposit rate can change once every six months and the deadline for amending the rate ahead of every six-month period is 1 June 2018. If the scheme is not amended by this date, the shortfall in the Bank’s funding will continue. The changes proposed by the order before us are sensible and proportionate measures in the light of the issues identified in the 2018 review. The order will ensure that the Bank’s important monetary and financial stability functions are fully funded, and for that reason I commend it to the Committee.

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My Lords, I noticed that when the Bank of England consulted on this scheme it received only three responses. That highly recommends that I be brief in my response. Obviously, we as a party very much value the independence of the Bank of England. I am reminded that Vince Cable spoke of it in his maiden speech in 1997, so we have a long history of wanting to see that independence firm and strong. Obviously, that means that the Bank of England needs the required resources to be able to function.

That is provided for under this statutory instrument, which permits both increases in the amount and indexation, which means that the amount can be reset according to shifts in the gilts on a six-monthly basis. That presumably reduces both volatility and risk to the Bank. The amount of money we are talking about is not particularly large. In most banking institutions it is somewhere lost well to the right-hand side of the decimal point.

As one of those who made the effort to respond noted, there is no assurance in any of the paperwork that we have seen that this is genuinely value for money and that the Bank has looked carefully at its expenditure. There appears to be no particular accountability for the way the money is spent. Will the Minister comment on that?

This also gives me the opportunity to raise a second level. Most of us here would agree that we are not really ready to see banks being let off the hook in terms of their contribution to the public purse. One could call this deposit scheme, in a strange way, a version of a hypothecated tax since it is a mechanism for providing funding to the Bank of England. I wonder whether the Government could provide clarity on their policy, because they are cutting the bank levy—a very significant amount of money—and raising this. Is there any relationship between the two? I hope that the Government will never pray in aid this particular increase as an argument that they are continuing to be tough on the banks.

I will make one last comment. This is exactly the kind of measure that should be dealt with through statutory instruments. It is exemplary. It is a relatively technical issue and relatively non-controversial. I hope that the Government will take on board that this is the kind of purpose for statutory instruments. They are not a mechanism for driving through policy, which we have seen in so many other areas.

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My Lords, I agree that this is clearly a measure that is appropriate for statutory instruments, but I wish that it had not landed on my desk. Of course, we will not oppose this. This will not be the one in 1,000 occasion this afternoon, I am sure the Minister will be pleased to hear. However, after I had taken the trouble to half understand the scheme, I could not believe its bizarre nature. I could not for the life of me see why there was not a straightforward fee-based scheme. The scheme is planned to raise £169 million per annum. Why does the Bank not simply send the banks a bill and raise the money directly? My real fear—which is rather the opposite of that expressed by the noble Baroness, Lady Kramer—is: what if this formula is wrong?

The functions covered by this income are absolutely vital. The austerity programme that this Government continue to pursue would be even more disastrous for the economy if it were not for the monetary measures taken by the Bank of England. This funding supports the MPC and the FPC, which are effectively seeking, through quantitative easing, the bank rate and the controls it puts on the banks, to control monetary policy and create an appropriate stimulus over this period of austerity. I see that the Bank has said that if the money is insufficient, it will reprioritise efficiency savings. I have worked long enough in the public sector to know what an efficiency saving is—it is called a cut in normal language. I cannot think of any area of the Bank’s activity, together with the resolution and recovery regime, that is more important. It is essential that it is properly funded.

The formula set out on page 5 of the Explanatory Memorandum has a number of components which I am afraid I do not understand. The first thing that it assumes is that the income required is fixed at £169 million for five years. Once again, I ask: what if that is wrong? The next factor in the formula is the aggregate eligible liabilities, which are fixed at £2.8 trillion—I hope that I have counted the number of noughts properly—yet the impact assessment assumes, from the various analyses that have been produced, that this figure will go up by 2.9% per annum. Why is it fixed if in fact the Government, in analysing the scheme, assume that it will increase?

In fact, the only real variable in the scheme is what is called on page 5 of the Explanatory Memorandum the “portfolio yield”—that is, the estimate of the yield from investments. It is made up of three parts: 55%, 42% and 3%. The 55%, labelled “a”, seems to be the only seriously variable one. It is a 13-year moving average. Why 55% and why 13 years? The second element, labelled “b” in the formula in paragraph 7.17(c), is calculated on a six-month average, but it is calculated only twice and is then fixed for the rest of the period of this notice. The 3% at the end of the formula is a six-month average calculated every six months. This is a ridiculously complex way to collect a modest amount of money. I believe that the whole system by which this money is collected needs to be reviewed. The fee-based approach would be simple to introduce. You could apportion the burden on eligible liabilities, which have to be calculated with this scheme. My biggest fear would then be coped with. A simple system could guarantee sufficient funds for this vital area.

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I am grateful to the noble Lord for delving into the algebra in the formula of “i” over “el” times “py”, which we all know arrives at the answer of the funding that is required. Before dealing with the explanation for that, I will deal with some of the points raised by the noble Baroness, Lady Kramer. She mentioned the consultation. The Treasury ran an informal consultation between 20 December and 15 January, contacting all the eligible institutions. A relatively small number of institutions contributed; 19 responses were received on that part. When it went into the public realm, between 8 and 9 March, three responses were received. One should not be surprised; it is a highly technical measure, as the noble Lord, Lord Tunnicliffe, said. Those were the points raised.

There was a point about what was being done to improve efficiency. There were changes to the way the Bank was to work. Cost-savings measures include a comprehensive programme of cost-containment and reprioritisation, coupled with an increasing amount of transparency, so we can track what is being spent at the Bank. Those elements are commendable.

The total tax burden on banks and building societies from the bank levy is significant. In 2016-17, £3 billion was raised from the Government bank levy above the £1.6 billion from the bank corporation tax surcharge. Those are significant sums contributing to the Exchequer.

The noble Lord, Lord Tunnicliffe, has been, as always, assiduous in the way he has delved into the detail of the Explanatory Memorandum and the order, and raised a number of pertinent points. He says: why not just have a levy, rather than an alternative means of funding that involves this level of complexity? The review considered a range of mechanisms by which the Bank’s monetary policy and financial stability functions could be funded, in particular whether a move to a fee-based model or levy would be appropriate. The review concluded that:

“Such a proposal was not possible within the scope of the existing legislation and in the current CRD review period. A fee-based model would require more in-depth analysis, starting from first-principles in terms of how costs could be apportioned in a fair and efficient way”.

The noble Lord also asked about the formula: what drives the variables and the weightings attached to them? There are different weightings in the order, which reflect the Bank’s long-term gilt holdings and investments over time. The long-term gilt holdings make up 55% of the total pool, hence the weighting of 55% is applied in the formula. Gilts that would be purchased in the coming months make up to 42% of the pool. Additional gilts that would be purchased over the remainder of the scheme to replace those that have matured amount to 3% of the portfolio.

He then asked: what happens if the Bank’s costs are below those expected? Do banks and building societies get their money back? That is a good question. The budget to be recovered by the scheme over the next five years is fixed and reflected in the order. Any surplus generated by the scheme as a result of underspend by the Bank will be retained by the Bank and will build up its capital base. This will in turn support the Bank’s monetary policy operations. Proposed amendments to the scheme seek to ensure that the Bank’s income profile is smoother over the next five-year period. That should ensure that a surplus or deficit does not arise under the scheme. Once again, I thank noble Lords for their questions and support on this. I commend this order to the Committee.

Motion agreed.