►
Description
www.parliament.scot
-
The Committee will meet at 9:45 am in the David Livingstone Room (CR6)
1. Decision on taking business in private: The Committee will decide whether to take items 4 and 5 in private.
2. Damages (Investment Returns and Periodical Payments) (Scotland) Bill: The Committee will take evidence on the Bill at Stage 1 from—
Alan Rogerson, Forum of Scottish Claims Managers;
Kate Donachie, Forum of Insurance Lawyers;
Norma Shippin, Director and Legal Advisor, and Joy Atterbury, Head of Litigation, NHS National Services Scotland;
James Dalton, Director of General Insurance Policy, Association of British Insurers.
3. Subordinate legislation: The Committee will take evidence on the Common Financial Tool (Scotland) Regulations 2018 [draft]from—
David Hilferty, Deputy Chief Executive, Money Advice Scotland;
Eileen Maclean, National Council Member for R3 in Scotland, R3 Scottish Technical Committee;
David Menzies, Director of Practice, ICAS;
Craig Simmons, Sector Co-ordination Manager, Money Advice Service.
4. Damages (Investment Returns and Periodical Payments) (Scotland) Bill: The Committee will consider evidence heard at today's meeting.
5. Work programme: The Committee will consider its work programme.
Not before 12.30 pm
6. Subordinate legislation: The Committee will take evidence on the Renewables Obligation (Scotland) Amendment Order 2018 [draft] from—
Paul Wheelhouse, Minister for Energy, Connectivity and the Islands, and Stewart Matheson, Senior Policy Adviser, Electricity Networks and Regulation, Scottish Government.
7. Subordinate legislation: Paul Wheelhouse, Minister for Energy, Connectivity and the Islands to move—S5M-14103 —That the Economy, Energy and Fair Work Committee recommends that the Renewables Obligation (Scotland) Amendment Order 2018 [draft] be approved.
Proposed future business
The Committee will next meet on 6 November. For further information, contact Alison Walker the Clerk to the Committee, whose details are economy@parliament.scot on extension 85403.
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A
Good
morning
and
welcome
to
the
29th
meeting
of
the
economy,
energy
and
Fair
Work
committee
for
2018
mask
everyone
in
the
public
gallery
and
otherwise
to
turn
any
electrical
devices
to
silent.
Please
and
the
first
item
on
the
agenda
is
a
decision
by
the
committee
to
take
items
four
and
five
in
private.
Are
we
agreed
on
that?
Yes,
thank
you.
We
now
turn
to
the
committee
looking
at
the
damages
investment
returns
in
periodical
payments,
Scotland
bill,
and
today
we
have
a
number
of
witnesses
on
our
panel.
A
First
of
all,
Kate
Donaghy
of
the
form
of
Insurance
lawyers,
then
Alan
Rogerson,
former
Scottish
claims
managers,
enormous
shipping,
director
and
legal
advisor
for
NHS
national
services,
Scotland
and
joy
Atterbury,
who
is
head
of
litigation
for
NHS,
national
services,
Scotland
and
finally,
but
not
least,
James
Dalton
who's,
the
director
of
general
insurance
policy
for
the
Association
of
British
Insurers.
So
welcome
to
all
of
you
this
morning.
Thank
you
for
coming
in
to
the
committee
and
can
I
just
say
that
your
microphones
will
be
operated
by
broadcasting.
A
B
So
what
we
are
very
supportive
of
is
this
legislation
which
changes
the
framework
to
one
or
that
offer
for
setting
the
rate
that
bears
much
more
relationship
to
what
happens
and
in
reality
it
is
a
much
more
modern
framework
and-
and
there
are
some
parts
of
it
that
we
might
come
on
to
it
later
in
discussion-
that
we
would
like
to
see
tweaked
but,
broadly
speaking,
the
old
framework
is,
is
broken,
and
this
new
framework
is
a
significant
improvement.
So.
C
Rogerson
I
just
wanted
to
add
when
one
of
the
things
that
occurred
to
me
is,
there
was
a
lot
of
talk
in
the
evidence
last
week
about
risk
of
us
seriously
injured.
People
are
risk
averse
because
they
need
to
provide
for
the
future
four
key
respects,
and
that
is
absolutely
true
and
I
fully
support
that
principle.
C
That's
probably
where
part
two
of
the
bill
comes
in
with
the
periodical
payments
where
you
have
someone
is
very
risk-averse
or
has
required
certainty.
That
is
exactly
where
PP
o--'s
come
in,
and
periodical
payments
would
be
operated
by
reference
to
a
wage
inflation
index,
for
example
for
care
workers
part
one
of
the
bill
where
we
talk
about
investment
choices,
that
an
injured
person
would
make
I
think
you
have
to
look
at
it
as
that
provides
flexibility
for
an
injured
person.
C
C
To
things
I
think
is
to
provide
the
flexibility
so
that
there's
a
clear
choice
there
if
you
required
absolute
certainty
for
the
future,
where
you're
risk
averse
or
you
have
a
certain
need-
that's
a
video
article
payment,
whereas
people
do
like
to
be
more
flexible
and,
in
my
experience,
injured.
People
do
like
to
take
that
lump
sum
and
have
control
over
the
future.
So,
for
example,
I
had
a
case.
I
should
say
my
day.
C
Job
is
working
as
a
Claims
Manager
for
Aviva,
as
well
as
the
former
Scottish
Claims
Manager,
either
case
two
or
three
months
ago.
We
are
the
settlement,
was
future
losses
in
the
form
of
loss
of
earnings
and
pension
losses,
and
the
injured
person
actually
decided
to
go
and
buy
a
house
and
they
mediate
after
marfa
settlement.
So
it
wasn't
so
much
about
the
choices
that
she
was
being
advised
to
make,
but
she
needed
the
flexibility
of
that
lump
sum.
C
D
I
think
it's
very
difficult
for
us
to
know
whether
people
are
over
or
under
compensated
with
their
damages,
because
we
don't
make
any
inquiry
after
the
case
has
settled
as
to
what
people
do
with
our
compensation.
But
what
we
try
to
do
when
we're
negotiating
a
settlement
has
come
to
a
fair
settlement
with
the
the
Purser's
agents
in
the
context
of
the
rules
that
are
available
to
us
at
the
moment.
D
And
what
we
have
found
is
that
when
you
settle
by
lump
sum
in
the
catastrophic
brain
injury
cases,
it
will
always
be
the
case
that
you're
either
overcompensating
or
under
compensating
because,
as
Lord
Stewart
said
in
the
D
against
gaiter
Glasgow
Health
Board
case.
The
one
thing
that
you
can
be
sure
about
is
that
you'll
get
the
life
expectancy
wrong
and
so
it'll
either
be
too
little
or
too
much,
and
so
either
you'll
be
giving
a
sum.
D
That's
going
to
be
too
high
or
too
low,
and
that's
why,
within
the
NHS
in
the
past
few
years,
we
have
moved
as
a
matter
of
practice
to
always
offering
periodic
payment
orders
when
it
comes
to
catastrophic
brain
injury
cases,
because
in
that
way
it's
the
right
thing
to
do
for
the
individual.
But
it
also
is
the
right
thing
to
do
for
the
NHS,
which
is
all
we
can
speak
for,
because
it
enables
that
life
expectancy
relate
to
be
taken
out
of
it.
So
I
think,
that's
probably
what
we
would
see
joy
is
Lindsey
I.
A
D
A
E
B
So
the
the
research
that
we
provided
to
the
committee
suggested
that
the
portfolio
of
assets
is
is
quite
a
conservative
one.
That's
been
determined
by
the
Scottish
Government
and
it
also
assumes
a
thirty-year
investment
horizon.
Now
those
two
things
taken
together
and
our
submission
make
that
a
very
conservative
low-risk
portfolio
of
investments.
B
Our
analysis
would
suggest
that
at
average,
life
expectancy
of
a
settled
claim
is
around
forty
to
forty
five
years.
So
so
30
years
is
very
short
and
in
that
context,
by
having
a
portfolio
that
is
underweight
on
equities
means
that
you're
not
hedging
your
inflation
risk
sufficiently.
So
if
you
were
to
increase
the
size
of
the
portfolio
of
equities
within
that
overall
portfolio,
you're
better
able
to
manage
that
that
inflation
risk
combined.
B
E
My
interest,
somebody
else,
will
explore
the
timescale
with
you,
but
but
by
definition,
equities
are
riskier
and
we
know
that
markets
go
up
and
markets
come
crashing
down
this
game.
Why
are
you
introducing
that
element
of
risk
to
somebody
who
wouldn't
be
engaged
in
this
discussion
if
they
weren't
injured
in
the
first
place?
Surely
risk
free
is
a
hundred
percent
company
compensation?
There's.
B
No
such
thing
as
risk-free
and
and
if
the
pursuer
wanted
to
pursue
an
option,
that's
that
very
significantly
reduced
their
risk.
As
was
said
earlier,
then
they
would
take
a
PPO
in
the
context
of
the
independent
financial
and
legal
advice
that
they
have
received
in
the
context
of
the
settlement
of
their
claim.
It's
for
that.
It's
for
the
claimant
to
choose
which
option
to
pursue
in
terms
of
the
portfolio.
It's
not
I,
don't
think
we're
suggesting
that
we
are
that
we
would
invest
in
the
portfolio
would
invest
in
East,
Asian,
IT,
startup
companies.
C
But
the
idea
is
that
people
injured
people-
Android
own
pension
investors
alike-
would
be
looking
to
invest
their
sum
for
the
future
and
get
the
best
possible
rate
of
return
but
being
properly
advised
by
proper
financial
advisors
to
make
sure
that
they
are
being
cautious
in
their
approach,
not
overly
cautious,
as
we
would
deem
the
portfolio's
at
the
moment.
Okay,.
E
Let
me
come
back
to
mr.
Dalton
then,
because,
in
its
submission
to
the
committee
of
the
Institute
and
faculty
of
actuaries,
noted
that
insurers
have
to
account
for
personal
injuries,
liabilities
on
a
risk-free
basis
why'd.
You
therefore
think
it's
fair
to
expect
pursuers
to
take
on
more
risk
than
insurance
companies
do
themselves
so.
E
B
Is
a
difference
between
the
discount
rate
in
terms
of
how
one
calculates
damages
in
personal
injury
cases
and
the
way
that
insurers
have
to
provide
capital
on
their
balance
sheet
from
a
solvency
perspective,
those
are
very
different
things.
The
risk
free,
an
advert
Acamas
rate
is
set
by
a
European
regulator,
the
European
insurance
and
occupational
pensions
Authority,
and
that
that
risk
free
rate
is
used
solely
to
value
liabilities.
It's
not
used
to
value
personal
injury
claims,
so
it's
about
valuing
the
like
long
term
liabilities
that
an
insurer
has
on
their
on
their
balance
sheet,
but.
B
The
principle
is
that
the
the
discount
that
the
risk-free
rate
that
is
applied
for
insurers,
valuing
liabilities
is
about
addressing
the
solvency
and
capital
issues
that
that
insurers
are
required
to
adhere
to
ensure
that
they
are,
they
retain
their
solvency.
Well,
in
this
context,
what
we're
talking
about
is
how
you
value
a
a
personal
injury
claim
that
has
a
longevity
to
it,
and
those
are
different
things
that
have
different
rates
that
are
reflected
in
it,
and
what
I
would
say
is
that,
in
terms
of
the
opah
risk
risk-free
rate,
they
are
never
negative.
B
G
C
Think
there
has
to
be
a
starting
point
of
assuming
what
people
will
do
as
part
of
the
settlement
process.
You
would
expect
an
injured
person
to
be
properly
advised
by
the
solicitors
and
financial
advisors
and
what
you're
looking
at
there
is
compensating
someone
for
the
future
loss
of
earnings,
the
pension
losses
and
the
future
care
needs.
C
So,
unfortunately,
the
way
that
this
country
has
been
approached
to
deed
is
to
look
at
what
sort
of
rate
the
Ratana
would
be
or
what
an
investment
would
be
and
an
actual
fight
you
may
get,
and
your
people
who
that's
exactly
what
they
choose
to
do
is
invest
that
capital
sama
for
the
future.
Some
people,
particularly
in
the
drawdown
pension
market,
for
example,
I,
did
draw
the
parallel
there.
The
likely
idea,
the
flexibility
that
allows
them
what
to
do
with
our
capital.
C
G
So
the
principle
is
that
we
do
need
a
discount
rate
because
we're
paying
a
sum
of
money
upfront
for
the
future
and
the
question
part
of
this
bill
at
least
the
first
part
of
it
is
about
how
to
set
that
discount
rate.
Could
we
move
on
to
the
the
question
of
the
30-year
period
that
is
contained
in
the
bill
as
part
of
the
assumptions
that
have
to
be
taken
into
account?
I
mean
we've
heard
from
mr.
G
C
I
would
just
add
to
that.
So
we
talked
a
little
bit
about
you,
aerial
tables
and
life
expectancy,
so
a
notional
30
year
period
for
the
portfolio,
so
the
expectation
of
a
56
year
old
male
in
the
UK
is
twenty
nine
point
six
four
years.
So
anyone
under
the
age
of
56
would
go
above
that
30
year
notional
period
for
women.
It's
twenty
nine
point.
Seven
six
is
life
expectancy
at
fifty
nine
years.
So
that's
why
I
think
the
thirty
year
period
is
perhaps
too
short.
C
Jersey,
for
example,
came
out
and
announced
yesterday
for
under
20
years
they
were
going
to
say
a
discount
rate
of
0.5%
for
periods
over
20
years.
They
were
looking
at
the
scan
rate
of
1.8%,
so
there
are
examples
out
there
around
the
globe
that
could
be
looked
at
and
it's
whether
the
committee's
may
need
to
to
consider
those.
H
Our
experience
is
probably
slightly
different
to
those
insurers,
in
that
the
cases
that
we're
principally
dealing
with
at
this
very
high
level
will
often
usually
be
babies
who
sustained
brain
damage
at
birth.
So
the
cases
are
being
settled
when
these
children
reach,
usually
about
eight
years
by
the
age
of
about
eight
years.
H
The
experts
will
usually
be
prepared
to
take
a
view
about
the
life
expectancy
of
that
child,
but
what
it
does
mean
is
that
life
expectancy
predictions
can
very,
very,
very,
very
hugely
thirty
years
in
some
cases
will
be
you
about
about
right,
but
it
may
be.
It
may
be
considerably
more
and
in
some
cases,
unfortunately,
it
can
be
considerably
less.
So
the
idea
variability
is
not.
H
C
Sorry
I
should
have
finished.
There
was
one
thing
to
speak:
there
sorry
I've
been
doing
serious
injury
claims
and
dealing
seriously
injured.
People
for
the
last
18
years
of
my
career
and
I
have
never
been
asked
to
settle
on
a
periodical
payment
basis.
Now
I
know
the
statutory
framework
has
not
been
in
place
in
Scotland,
but
a
voluntary
framework
has
been
in
place
for
a
good
while
now
and
I've
still
never
been
asked.
C
F
G
Thank
you
just
further
on
that.
On
the
thirty-year
period
I
mean
in
the
in
health
cases,
you
may
I
mean
that
you
just
indicated
you
may
have
claims,
that's
being
settled
for
people
whose
life
expectancies
really
rather
short
five
years.
Maybe
yes,
does
that
add
to
the
argument
for
having
a
bit
more
flexibility
around
the
assumptions
one
mix
about
the
period
over
which
a
portfolio
will
be
invested
or
not?
Yes,.
H
D
Guess
when
you
change
the
discount
rate,
because
it
may
seem
like
a
small
percentage,
but
it
has
a
huge
impact
on
the
future
value
of
a
lump
sum
payment.
So
the
point
Joy's
making
is
that
if,
if
you've
actually
got
it
wrong
and
you've,
given
a
lump
sum
beast
on
a
negative
discount
rate,
it
could
be
a
very
high
figure
that
then
it
ends
up
not
actually
doing
the
job.
It
was
meant
to
do
because
the
individual
has
died.
D
A
Does
that
mean
that
you
think
the
review
period
suggested
of
three
years
for
a
review
of
the
discount
rate
when
we
get
on
to
that
is
too
short,
because
I
think
there's
3,
5
or
7
year
period
suggested
in
the
various
submissions
to
this
committee?
What
are
your
views
on
these?
Just
very
briefly
before
we
move
on
to
questions
from
John
Mason,
Alan,
Rogerson
and.
C
I
would
certainly
advocate
a
five-year
review
period
three
years
and
my
experience
is
a
little
too
short.
The
reason
I'm
saying.
That
is
because
it
may
be
that,
in
the
run-up
to
a
review
that
either
party
either
side
sees
an
advantage
in
holding
off
not
settling
the
case
at
that
point
in
time,
because
there's
some
perceived
advantage
of
waiting
to
perhaps
get
a
more
advantageous
terms
after
a
review
period,
so
I
think
a
five-year
cycle
would
allow
a
more
stable
period
than
between
times
now.
C
I
know
that
is
also
allied
with
I
think
there
were
some
questions
that
owned
how
an
injured
person
would
choose
to
invest
the
damages
and
what
sort
of
advice
they
would
get,
because,
obviously
you
would
expect
that
to
be
reviewed
annually
if
they
had
a
managed
portfolio.
So
I
strongly
suggest
that
five
years
would
be
the
way
to
go
and
that
to
stop
people
trying
to
take
advantage
in
the
lis
settlement
on
the
system
or
take
advantage
of
the
review
period
to
for
uncertainty.
Just.
F
See
that
my
experience
and
in
the
lead-up
to
the
change
to
the
week
we
now
have,
and
since
that
REIT
was
fixed
with
the
consultations
are
happening
here
and
safe
of
the
border,
it
has
impacted
on
litigation
behavior
and
it
has
made
it
more
difficult
to
settle
cases.
So,
although
personal
injury
cases
are
managed
on
a
timetable
by
the
court,
the
more
complicated
cases
take
longer
and
there's
a
period
where
you
may
be
waiting
a
year
or
even
two
for
a
court
hearing
and
that's
time
that
can
be
used
between
parties
to
negotiate
a
settlement.
F
A
F
A
D
I
J
Thanks
very
much
convener
Andy
I
think
to
continue
the
theme
of
the
discount
rate
here.
We
also
have
this
fact
the
further
adjustment
of
half
a
and
no
on
last
week's
panel
we
sell
had
one
witness
that
argued
strongly
that
they
felt
that
the
pursuer
is
disadvantaged
to
start
with
that
they're
taking
on
the
risk
of
maybe
living
longer
than
they
would
be,
that
inflation
is
bound
to
be
higher
than
the
any
rate
we
say
it,
because
we
just
tend
to
go
up
faster.
J
B
If
I
could
start
on
that,
maybe
and
I
think
the
problem
is
that
we've
seen
no
evidence
of
the
problem
and
and
I
think
in
our
submission.
The
you
can
make
a
political
or
policy
judgment
about
whether
you
want
to
overcompensate
and
I.
Think
what
the
government's
policy
memorandum
makes
very
clear
is
that
are
seeking
to
achieve
this
hundred
percent
principle
of
of
competent
of
compensation.
B
But
then
they
have
included
within
the
framework
for
sitting
the
discount
rate,
the
zero
point,
five
percent
further
margin
which,
by
definition
overcompensates
now
that's
a
political
and
policy
choice
and
my
submission
to
you.
That
is
a
very
blunt
instrument
with
which
to
achieve
that
policy
objective
and
an
an
our
submission.
What
you,
if
you've,
made
a
decision
that
you
want
to
err
on
on
the
side
of
overcompensation
and
you're
being
transparent
about
that?
B
What,
rather
than
using
the
very
blunt
0.5%,
further
margin
deduction,
what
you
could
do
is
determine
what
the
actually
assessed
raters
and
then
round
that
down
to
the
nearest
0.25
percent,
so
that
will
provide
you
with
over
compensation,
but
not
to
the
extent
of
a
very
sick.
The
very
significant
costs
associated
with
a
blunt
0.5%
reduction,
okay.
C
Would
just
add
to
that?
If,
if
the
portfolio
is
already
over
cautious
as
we
would
submit,
then
as
James
says,
the
extra
0.5
is
quite
a
blunt
instrument
to
then
take
it
into
overcompensation
territory
and
if
there
were
to
be
over
compensation
in
the
cost,
would
likely
to
be
borne
by
insurance.
Premium.
Peers
in
Scotland
businesses
and
the
public
sector
alike.
C
J
C
Are
and
I
think
one
of
the
final
members
say
that
previously
we
don't
necessarily
get
to
see
what
the
injured
person
does
with
the
settlement
as
an
way
negator,
which
to
me
would
be
the
best
evidence
to
help
inform
the
committee
is
to
exact
investment
behaviors
of
Avenger
people,
but
for
me
I
always
take
it
back
to
the
availability
of
periodical
payments
and
the
fact
I've
never
been
asked
for
one.
So
lump
sums
must
be
working
for
people.
C
J
C
J
I
think
one
of
my
colleagues
is
going
to
ask
more
about
periodical
payments,
but
I
think
we're
kind
of
given
other
evidence
that
people
the
rather
reasons
people
wanted
a
the
lump
sum.
Okay
on
that
one
note
I
suppose
moving
on
from
that,
then
is
the
the
whole
question
of
the
methodology
of
calculating
the
discount
rate,
and
the
plan
is
that
the
UK
government
actually
will
be
a
player
in
this,
but
also
the
government
could
maybe
change
the
notional
portfolio.
I
mean
I'm,
an
accountant
I,
quite
like
the
idea
that
it
could
be
completely
automated.
J
B
That's
a
that's
a
decision
for
policymakers,
I,
think
I
mean
I,
I,
suppose
I'm
I'm,
a
supporter
of
technology
and
technological
advances,
I'm
slightly
cautious
about
automating,
a
process
that
will
ultimately
have
such
a
profound
impact
on
people's
lives
and
people
who
are
the
most
seriously
injured.
People
in
society
I'd
be
very
cautious
about
automating
that
process
and
I
think
exercising
human
judgement,
and
these
decisions
is
probably
for
now
at
least
the
best
pace
to
remain.
B
F
I
would
just
say
that
the
discussion
that
we're
having
today
and
the
discussions
that
you've
had
around
the
discount
read
highlight
the
difficulty
of
what
it
is
you're
doing
when
you
fix
a
discount
rate
and
a
nice
and
attractive
thought.
What
might
be
to
think
you
could
offer
me
that
I'd
I
think
it's
a
difficult
process
that
cannot
be
reduced
to
another
medical
formula.
I,
don't.
J
J
F
Think
it's
difficult
to
know
how
it
work
in
practice.
The
Scottish
Ministers
retain
the
control
in
the
current
bill
to
fix
a
notional
portfolio
and
and
to
fix
the
standard
adjustments,
but
the
government
actually
would
have
the
final
C
on
what
the
figure
is.
I
think
it's
not
entirely
as
miter
stand
with.
Accountability
for
the
decision
would
lie.
Mm-Hmm.
C
Yes,
I
was
just
going
to
say
it's
England
and
Wales
has
been
a
slightly
different
route
than
that.
It's
the
Lord
Chancellor
with
our
panel
of
special
advisers,
will
specify
the
portfolio
to
the
the
government
I'd
Chile's
Department
as
I
gather
it,
whereas
the
approach
that's
been
taken
so
far
by
the
Scottish
government
is
a
Scottish
government,
say
the
notional
portfolio
the
adjustments
and
set
the
parameters
for
the
government's
actuaries
Department.
C
So
it's
really
a
question
for
the
committee
as
to
which
direction
you
want
to
take
it,
and
it's
really
a
policy
decision,
because
both
options
might
arrive
at
similar
figures
or
they
might
completely
depart
in
different
different
avenues.
So
your
strong
feelings,
one
way
or
the
other,
particularly
not
particularly
no
I,
think
as
long
as
we
recognize
what
we're
doing
and
what
route
we're
going
down,
and
we
do
it
for
the
right
decisions.
Then
we've
got
to
wait
and
see
what
transpires.
Okay,.
C
Possibly
you
do
have
the
situation
where
injured
people
and
I'll
draw
the
parallel
back
to
draw
down
investors
again:
they're,
investing
in
the
same
market
and
that
markets,
you
key
wife.
So
if
you've
got
a
different
discount
rate
in
England
and
Wales
than
you
do
in
Scotland,
there's
an
end
result,
then
the
you
might
have
more
costs
being
passed
on
to
Scottish
premium
via
an
insurance
market
or,
conversely,
if
the
discount
rate
is
Lord
in
England
and
Wales,
then
England
and
Wales
and
premium
pairs
with
the
king
war.
A
C
G
It's
just
a
brief
supplementing
this
I
mean
it's
been
mentioned
before
about
insurance,
premium
players
and
tax
payers.
Paying
for
this,
have
you
could
any
figures
on
the
centage
of
the
total
insurance
payouts
or
total
compensation
from
health
boards,
and
it
has
what
percentage
of
that
is
in
fact,
lump
sums
for
pension
injury
claims,
I.
G
C
A
it's,
a
very
small
proportion
of
the
overall
total
of
numbers,
but
you
are
dealing
with
the
the
highest
value
claims
at
the
other
end
of
the
spectrum,
says
very
difficult
to
know
exactly
where
the
truth
lies.
I
can
certainly
I
can
talk
for
my
own
company
and
my
own
employer
to
say
this
part
of
the
web.
C
C
A
B
D
In
some
information
to
the
committee
about
this
part
of
the
problem
is
that
because
there
are
a
small
number
of
claims,
if
we
give
the
figures,
it
could
pretend
to
identify
the
person
so
we're
reluctant
to
actually
give
the
actual
figures
on
an
annual
basis,
but
we
could
do
it
over
we've
done
it
over
a
period
of
years.
We
could
shorten
that
period
of
years
to
five
years.
Perhaps
yes,.
A
If
you
could
do
it
in
an
anonymized
form
loop
so
as
to
give
us
to
give
the
committee
some
understanding
of
the
answer
to
to
that
particular
point:
okay,
Donaghy!
If
you're,
you
would
be
in
a
position
to
comment
on
that,
but
perhaps
if
I
can
leave
that
with
the
the
panel
members
and
indeed
on
any
other
question
that
has
been
raised
today,
please
don't
hesitate
to
write
and
add
to
what
are
the
submissions
you
put
and
already
I
come
now
to
:
BTW
thank
convener.
I
H
H
So
I
mean
the
numbers
are
very,
very
small,
but
what
those
will
show,
for
example,
is
that
in
2016-17
we
had
one
lump
sum
settlement
over
a
million
and
two
PP
o--'s
in
2017-18.
We
had
one
lump
sum
settlement
over
a
million
pounds
and
two
PP
o--'s,
so
the
numbers
are
extremely
small,
but
our
our
desire
is
to
settle
these
by
people
and
there
are
a
number
you
under
negotiation
at
the
current
time,
am.
I
I
correct
and
taking
from
what
you
said
that
it's
mainly
children,
yes,
that
fall
into
this
category.
Yes,
for
obvious
reasons,
yes
and
for
the
rest
of
the
panel
there's
very
little
experience
of
PP
o--'s
in
Scotland.
Correct
can
I
just
ask
some
of
the
evidence
that
we've
seen
as
a
over
the
last
period
suggests
that
the
regulatory
regime
for
insurers
makes
it
expensive
to
offer
PP
o--'s.
Are
there
any
issues
with
the
regulatory
regime
that
would
indicate
that.
B
So,
as
I
was
explaining
in
response
to
an
earlier
question,
they
the
way
that
insurers
have
to
reserve
for
their
long
term.
Liabilities
is
say
in
a
very
different
way,
from
the
way
that
the
the
discount
rate
is
set
and
they
hold
capital
based
on
those
long
term
liabilities
and
in
direct
answer
to
your
question,
is
no
problem
with
that
regime.
B
C
I
think
there
was
some
evidence
last
week
that
there
may
be
a
problem
with
insurers
and
solvency
and
and
how
it's
backed
in
shooters
on
the
right
business
in
the
UK
are
subject
to
the
FSC
s:
rules
on
the
guarantee.
So
essentially
there
wouldn't
be
a
problem
with
an
insurance
company.
If
an
insurance
company
wasn't
able
to
fulfill
the
PPO
and
went
bust,
then
the
government
would
step
in
and
replace
that
so
perhaps
the
motor
insurers
Bureau.
C
So
that's
one
aspect
where
you
perhaps
need
to
look
at
the
bill
because
I
don't
think
the
motor
insurers,
Bureau
or
a
name.
That's
a
compensator
for
the
purpose
of
periodical
payments
at
the
moment,
but
I
think,
despite
any
perceived
issues
over
the
insurance
industry
and
whether
we
like
PP
ORS
or
don't
like
PP,
o--'s
or
whatever
I,
don't
think.
That's
necessarily
the
right
question.
I
In
fact,
you've
just
touched
on
something:
I
was
going
to
be
asking
anyway,
which
is
relating
to
the
bills
requirement
for
reasonable
security.
You
know
enough
to
keep
the
continuing
payment
going.
No,
you
talked
about
insurance
companies
and
obviously
there's
backing
there,
and
probably
any
court
would
say
that
the
properly
constituted
insurance
company
would
give
reasonable
security.
But
there
are
other
bodies,
I
mean,
maybe
even
the
NHS,
for
example,
would
a
court
other
bodies
that
the
court
would
not
see
as
be
able
to
supply
that
reasonable
security.
B
Point
about
the
context
of
the
motor
insurers
Bureau,
so
a
number
of
of
claims
are
settled
as
a
result
of
accidents
with
uninsured
drivers
and
the
motor
insurers.
Bureau
settles
a
number
of
those
cases
on
a
PPO
basis.
So
what
we
would
appreciate
if
in
this
legislation,
is
that,
rather
than
they
might
be
needing
to
go
to
court
every
time,
it
wants
to
settle
a
case
to
demonstrate
to
the
court
that
it
has
got
the
solvency
and
it's
got
the
capital
to
provide
that
PPO
on
a
long-term
basis.
B
I
C
D
I
think
called
structured
settlements
a
number
of
years
ago,
before
PP
o--'s
came
in
in
their
current
format
and
in
the
days
of
the
Trust's
they
don't.
If
you
remember,
the
NHS
trusts
used
to
be
considerable
amount
of
discussion
about
whether
that
would
be
something
that
would
continue
into
the
future
and
indeed
they
didn't.
But
it
would
think
it
was
always
recognized
by
pursuers
agents
that
there
would
be
some
mechanism
of
payment
for
a
health
service
organization
or
a
government
organization.
But
even
was
a
question.
D
C
C
K
L
Mcdonald,
if
you
know
I
want
to
continue
in
a
same
discussion
on
about
PP
o--'s,
but
in
particular
about
the
variation
of
PPOs,
our
future
date
welfare
this
morning
that
PP
o--'s
could
reduce
the
chance
of
somebody
being
over
or
under
compensated.
That
brings
a
bit
of
certainty
and
the
fact
that
somebody's
life
expectancy
could
change
a
future
date,
so
PP
o--'s
will
be
helpful
to
ensure
that
they
get
the
award
that
they
require
so
without
government.
That
degree
of
certainty
would
I
be
right
in
saying
that
no
concerns
about
courts,
variant,
PP,
o--'s,.
D
You
need
to
be
very
clear
in
the
guidance
as
to
what
particular
circumstances
you
would
envisage.
The
people
could
go
back
to
the
court
to
change
or
remain
the
PPU,
because
one
of
the
advantages
about
settling
a
case
is
that
you
achieve
certainty
for
both
the
defendant
and
the
pursuer,
and
so,
if
it
becomes,
if
the
I
think
it
would
be
written
into
the
agreement,
you
know
when
those
circumstances
might
arise,
but
I
think
it
would
be.
D
L
F
Have
a
system
of
provisional
damages
which
is
used
in
the
mean
when,
when
we're
looking
at
people
who
have
developed
a
disease
and
from
exposure
to
something
perhaps
at
work,
and
they
have
a
relatively
minor
condition
which
would
indicate
they
have
been
exposed,
but
there's
a
risk
that
in
the
future
they
will
develop
a
more
serious
condition
and
the
provisional
damages
regime
allows
them
to
have
some
compensation
now
for
the
relatively
minor
condition,
but
reserve
their
right
to
come
back
to
seek
damages
in
the
future.
If
they
do
develop.
F
A
more
serious
condition
and
foil
submission.
Is
that
the
wording
in
relation
to
PP
o--'s
and
their
variations
shouldn't
matter?
The
wording
for
provisional
damages,
because
there
has
been
a
fair
amount
of
argument
in
court
about
what
a
significant
deterioration
or
improvement
means
and
if
you
tied
it
to
that
wording,
you're
benefitting
from
what's
already
been
done
before
I
think.
The
legislation
also
envisages
that
you
would
write
into
the
agreement,
things
that
might
change
life
expectancy
or
or
need
for
care.
F
C
And
be
that
it's
not
it's
not
for
primary
legislation.
To
consider
that
it
may
be
that
the
Scottish
civil
justice
council
and
secondary
legislation
of
rules
of
court
can
take
account
of
this.
But
I
I
do
understand
that.
Obviously
it's
for
the
committee
to
make
sure
that
the
headline
legislation
is
fit
for
purpose
and
enables
all
this
to
take
place.
L
F
That's
again
something
that
it's
going
to
be
in
the
detail,
but
if
someone
is
compensated
because
they
have
been
harmed
by
someone
else's
fault,
then
you
don't
have
any
broad-brush
basis.
It
seems
right.
The
person
who's
caused
the
harm
should
pay.
The
cost
of
that
I
think
the
concern
would
be
you.
You
could
have
a
vexatious
person
who
keeps
bringing
someone
back
to
court
and
I
think
in
those
circumstances
you
need
to
look
at
safeguarding
the
defender
in
those
circumstances,
but
that
is
really
something
for
the
the
detail
of
rules.
F
Court
rules
and
in
terms
of
I
was
it
was
mentioned
last
week,
quacks
qualified
when
we
cost-shifting,
which
is
coming
in
the
the
detail
of
that
system,
is
currently
being
looked
at
by
the
Scottish
civil
justice
council,
and
so
this
is
something
they
could
also
look
at
and
I
think.
The
detail
that
would
need
to
be
there
would
be
appropriate
for
the
rules
came
so
to
look
at.
A
Just
to
pick
up
on
that
last
point
that
you
made
Kate
Donaghy
I'm,
just
looking
at
your
foil
submission
to
the
committee
and
I
think
you're,
referring
to
the
issue
about
sanction
to
ETA
in
the
bill
and
you've
said
to
change
the
wording
to
the
current
wording.
Significant
improvement
or
serious
deterioration,
rather
than
I
think
the
wording
in
the
bill
a
change
in
the
for
serious
physical
or
mental
condition,
and
is
that
because,
if
there's
a
new
wording,
then
the
courts
will
have
to
determine
what
that
means.
A
F
A
F
It's
going
to
be
I
think
if
the
wording
reflect
heat,
the
professional
damage
is
worth
doing.
Then
people
know
broadly
what
what
they're
dealing
with
and
the
level
of
change
that
would
be
required
to
justify
bringing
something
to
court,
how
the
expenses
situation
works
with
that
and
any
sanctions
for
people
being
vixx's
on
either
side.
I
think
that
level
of
detail
is
for
the
rules
counsel
to
determine
right.
A
F
Think
the
wording,
the
description
of
the
the
change
in
circumstances.
It
would
be
helpful
if
it
mattered
to
the
administration
of
justice
act
in
relation
to
provisional
damages
I.
Think
the
detail
beyond
that.
It
would
make
sense
for
that
to
be
determined
by
the
Scottish
civil
justice
came
self.
All.
A
Right,
thank
you
any
other
questions
from
committee
members.
If
not,
we
have
a
little
bit
of
time.
So
I
don't
know.
If
each
of
you
wants
to
state
two
sort
of
in
one
or
two
sentences,
the
the
key
points
that
you
think
we
should,
as
a
committee,
take
away
from
you.
On
the
other
hand,
you
may
not
wish
to
because
you
may
feel
that's
a
limiting
too
much
what
you
said
and
you've
put
in
your
submissions
but
we'd.
A
A
A
A
A
A
Well,
welcome
back
to
our
session
this
morning
we
now
turn
to
look
at
the
subordinate
legislation,
common
financial
tools,
Scotland
regulations,
2018
and
we're
joined
today
by
David
Hilferty,
deputy
chief
executive
of
Money
Advice
Scotland,
welcome
to
you,
Eileen
McLean,
national
council
member
for
r3
in
Scotland,
David
Menzies,
director
of
practice
I
cass
and
craig
simmons
sector
coordination
manager
of
Money
Advice
service.
So
welcome
to
all
four
of
you
this
morning.
A
Thank
you
for
coming
in
and
the
microphones
will
be
operated
by
the
sign
desk,
so
no
need
to
push
any
buttons
if
you
want
to
come
and
just
raise
your
hand
to
indicate
that
to
me,
no
need
to
answer
every
question,
but
please
feel
free
to
contribute
to
the
discussion.
As
we
move
to
committee
members
questions
starting
now
with
Angela
Constance
good.
M
Morning
to
the
panel
I
have
three
questions
that
are
essentially
to
explore:
the
the
desire
for
a
common
financial
and
some
of
the
pros
and
cons
and
around
that.
So
can
I.
Ask
the
panel
that,
given
that
one
of
the
key
arguments
for
the
adoption
of
the
standard
financial
statement
is
that
it
will
standardize
the
assessment
of
income
across
the
UK,
how
important
do
you
think
this
is
and
what
impact
will
that
have
in
debtors
of
having
stricter
limits
or
an
expenditure
and
I
don't
mean
to
start
a.
N
Coffin
I
am
I,
represent
our
three
and
it's
our
members
as
insolvency
practitioners
who
will
be
putting
the
s
FS
into
practical
practice
or
an
appointment
and
obviously
the
basis
of
the
regulations.
I
think
the
earthly
position
is
that
it
is
definitely
prepared
will
to
have
a
standard
one
of
the
difficulties
up
until
the
introduction
of
CF
was
that
there
was
a
number
of
different
standards
out
we're
some
firms
who
choose
a
British
banking
association.
Some
would
use
what
was
then
triple
CS
some
reduce
none
at
all.
N
We
would
have
an
individual
and
what
we're
really
aiming
for
with
CF
t
or
no
s.
Fs
is
a
common
platform
of
analysis
and
we've
had
that
in
Scotland.
For
a
number
of
years
now
s
FS
is
UK
white
and
again,
I
think
preferable
to
have
something
like
that.
The
fact
that
we
have
different
solutions,
north
and
south
of
origin
terms
of
date,
solutions
is
well
recognised.
With
the
majority
of
the
creditor
organizations
are
no
beast
predominantly
Manchester.
N
We
have
had
issues
in
the
past
where
they
didn't
necessarily
recognize
a
Scottish,
specific
approach,
because
they
just
didn't
see
on
a
sufficient,
a
basis
to
be
familiar
with
it,
so
the
FSA
s
FS
across
the
UK
basis.
We
definitely
support
that
aim,
ease
of
use
for
everybody
and
our
common
platform
for
advice.
Okay,
before.
M
O
Think
somewhat
Eileen,
you
know,
I
think
the
the
principle
of
a
common
financial
tool
is
one
that
we
would
generally
support
and
I
think
broadly
across
the
UK.
It
makes
sense
to
have
a
similar
method
of
calculation
when
the
the
bankruptcy
in
debt
advice,
Act
or
bill
was
being
discussed
within
Parliament.
This
was
I,
guess
the
first
time
that
the
common
financial
tool
was
was
brought
in
and
we
certainly
you
know,
suggested
at
that
point
that
actually
neither
point
the
the
common
financial
statement
probably
wasn't
the
right
method
to
use
it.
In
the
first
place.
O
K
P
Morning
and
thank
you
also
for
inviting
us
to
speak
out,
I'm
Craig
I
work
for
the
Money
Advice
service
and
we
kind
of
are
the
owners
of
the
might
of
the
standard
financial
statement.
It's
worth
just
mentioning.
The
standard
financial
statement
has
been
built
on
the
good
practice,
what's
already
in
existence
in
the
sector.
So
there's
something
called
the
common
financial
statement
which
is
currently
in
that
common
financial
tool.
There's
an
approach
that
step-change
use.
P
A
lot
of
insulting
practitioners
also
use
across
the
UK,
and
there
are
various
other
approaches
used
to
assessing
and
affordability
when
people
are
in
problem
debts
and
what
we
try
to
do
is
take
what's
worked
well
in
all
of
those
other
existing
formats
and
we've
learned
a
huge
amount
actually
from
what's
happened
in
Scotland.
The
savings
cat
agree
is
a
prime
example
of
that.
She,
where
some
of
this
worked
here
in
an
example
of
something
that's
been
built
into
the
standard
financial
statement
and
I.
P
P
He
and
the
standard
financial
statement
means
that
there
only
be
one
approach
to
that
across
the
debt
advice
sector
and
why
I
think
that's
really
important
for
clients
is
that
if
you
go
one
place
in
recessions
in
one
method,
the
output
may
be
slightly
different
to
what
ends
up
being
India
or
common
financial
tool
output.
Another
thing:
that's
a
great
customer
experience
to
have
that
change.
P
You
may
go
to
a
different
provider
who
can
provide
that
particular
solution
and
an
IP,
for
example,
who
would
say
well
actually
spending
guidelines
in
this
format
is
different
to
the
one
you
know
one
has
been
used
previously,
so
it
should
reduce
burden
on
both
advice
providers,
and
so
many
practitioners,
but
most
importantly
for
me
on
clients
are
in
their
hour
of
need,
who
need
a
seamless
journey.
Thank.
K
Reviewed
us
from
the
perspective
of
our
members
or
front
Limon
advisors,
so
of
the
almost
a
two
and
I
did
today
basis,
no
I.
Think
if
you
patch
that
same
question,
our
members,
there
is
only
response,
you'd
get
back
from
them,
as
that
we've
already
had
standardized
assessment
of
income,
sense
and
adoption
of
the
CFT
in
2015,
so
what
they
are
more
likely
to
view.
K
That's
a
question
of
how
important
as
it
that
we
replace
our
existing
standardized
assessment
of
income
with
a
new
standardized
assessment
of
income,
which
hasn't
nearly
steady,
current
system
and
work
should
kick
in.
Sales
is
going
to
lead
to
more
walk
through
additional
revenue
requirements
and
they
have
those
requirements
are
something
that
mother
Shawn
throughout
this
session,
but
I
think
that's.
We've
got
a
practical
deference
for
kinds
of
Scotland
compared
to
clients
and
England
and
Wales.
The
approach
from
the
killing
by
crops
in
Scotland
means
that
the
evidence
requirements
are
more
onerous
than
elsewhere.
K
Then
what
we've
got
with
this
standard
financial
statement
as
moving
up
self,
think
actively
swear
that
they
will
always
be
evidence,
those
catalyst
and
quit
transport,
then
good
school
uniform
course.
They
include
the
course
culture
things
that
are
difficult
to
evidence,
so
that
would
be
the
viewpoint
of
our
members
and
that
would
be
some
of
the
impacts
on
clients
in
their
that
start
to
melt
every
transaction
towards
that's
new,
but
second,
standardized,
assessment
of
income.
Okay,.
M
Thank
you
for
that.
So,
following
on
from
a
diva
Telfair
teased
point
of
view,
I
mean
Kate
and
clean
had
and
her
contribution
acknowledged
that
Yuki
caters
already
have
to
adapt
to
specifically
discuss
processes.
So
I
suppose
and
I'll
put
this
question
to
David
hell.
31St
doesn't
make
a
practical
difference
if
Scottish
statutory
date,
solutions
use
a
different
income
assessment
method
and
I
think
you
began
to
touch
upon
here.
The.
K
First
thing
I
would
say
when
I
speak
to
our
members,
when
I
speak
to
our
money
advisors,
the
difficulty
that
they
have
in
dealing
with
creditors
isn't
with
your
conventional
consumer
creditors,
which,
as
I
said
our
best
through
the
UK
consumer
credit,
those
banks,
Randle's
credit
card
firms
and
so
on.
They
have
numerous
approaches
in
place
to
deal
with.
Customers
of
considered
vulnerable
customers
and
low-income
and
advisors
will
tell
you
that
dealing
with
these
types
of
creditors
is
relatively
straightforward.
K
From
the
most
part
will
the
difficulty
often
arises
as
in
dealing
with
what
you
made
a
filter
is
public
sector
Thorsen
dealing
with
DWP
and
dealing
with
HMRC
I'm,
primarily
dealing
with
local
authorities,
who
often
recover
chemicals
taxi
deals
trustee
aggressively.
So
the
notion
that
previously
advisors
have
had
problems
trying
to
negotiate
with
consumer
credit
force
is
not
something
that
our
members
will
necessarily
recognize.
K
Turning
to
your
second
point
about
the
impact
and
start
to
the
solutions
when
you're
going
through
a
start
to
a
solution,
the
evidence
requirements
that
need
to
be
backed
up
within
the
financial
statement,
as
I've
said,
can
bonus.
In
many
cases,
I
mean
we've
seen
examples
of
cases
where
a
father
who
don't
love
was
his
daughter
was
asked
to,
or
has
expenditure
to,
visit
his
daughter
by
train
fare
which
can
sell
that
excessive
we've
seen
examples
of
a
disabled
client
who
was
asked
to
evidence
expenditure
on
incontinence
pads.
K
Now
these
are
issues
that
you
don't
necessarily
have
elsewhere
and
the
Yuki,
but
the
we
do
have
as
part
of
our
approach
the
statutory
solutions
and
Scotland
now
what
they
say.
First
does
as
it
moves
as
I
said:
elements
like
transport
and
school,
uniform
cost
and
the
catalyst
which
must
be
evidenced,
and
that
wasn't
previous
the
case
in
CFS.
That's
before
we
even
start
to
talk
about
Java,
which
I
got
forgot:
bleaches.
K
Yes,
when
that
sense,
also
an
increase,
what
put
on
advisors
on
clients
and
on
the
OB
as
well
for
that
matter,
unless
we
get
a
possession
where
those
are
a
reasonable
approach.
Decadence-
and
in
that
case,
that
would
alleviate
a
lot
of
our
concerns
and
that
really
I
learned
these
heinous
requirements.
Okay,.
N
Think
the
wager
issue
is
that,
from
a
credit
perspective,
if
you
have
no
standard
whatsoever,
we
go
back
to
your
scenario.
We're
there's
a
huge
subjective
overview
and
what
you
have
are
individual
creditors,
whether
they're
local
authority,
small
traders,
who
will
express
an
opinion
on
a
dater
sustained
and
you
we
will
get
down
to
whether
we
should
have
sky
telly,
whether
they
should
smoke,
whether
they're
allowed
to
go
and
visit
their
daughter
and
what
they
support.
They're
spending
their
money
on
at
the
end
of
the
day.
N
There's
all
sorts
of
privacy
issues
and
date
is
not
a
crime.
You
know,
and
what
we're
really
aiming
for
here
is
our
standard
of
living.
So,
if
you
say
our
standard
against
which
the
average
is
in
benchmark
and
and
all
will
come
back
to
checker
figures
as
long
as
you
have
some
kind
of
benchmark,
it's
actually
harder
for
for
creditors
to
argue
because
you're
using
a
standard
against
which
everybody
is
the
measured
on
a
common
basis.
O
Again,
I
think
you
know
similar
to
David.
There
I
think
it's
the
the
level
of
evidence
requirements,
the
the
that's
the
onerous
part
of
this
at
the
moment.
I
think
it
does
make
absolute
sense
for
everyone
to
be
to
be
assessed
in
a
common
way
in
a
standard
way
with
within
a
defined
framework
in
terms
of
UK
credit
or
positions.
I
think
you
know,
they're
well
used
to
dealing
with
slightly
different
nuances
of
Scots
law
and
slightly
different
procedures
that
we
that
we
have
and
I
think
particularly
around
the
assessment
of
contributions.
O
It
certainly
benefits
them
to
be
able
to
do
that
on
a
common
base
basis
across
the
UK,
whether
it's
somebody
entering
into
Liva
in
England,
Wales
or
Northern
Ireland,
or
somebody
entering
into
a
trust
deed
or
our
debt
arrangement
scheme
arrangement
in
Scotland.
If
there's
that
sort
of
commonality
across
across
the
the
board
there,
it's
certainly
beneficial
for
them
where
they
have
a
discretion
as
to
whether
they
want
to
permit
that
data
to
go
into
that
solution
or
whether
they
they
don't
and
they're
able
to
assess
that
far
far
easier.
Then
thank.
P
The
point
also
around
evidencing
of
trigger-finger
breaches
I
think
is
certainly
going
to
court
more
during
this
discussion.
But
I'm
most
touched
on
the
reasons
why
travel
things
like
the
scription
costs
sort
of
school
meals
have
gone
into
what
we
would
call
the
fixed
expenditure
cost
and
it
forgive
me
if
I'm
telling
the
committee
what
they
already
know
coming
to
the
fix
committee,
that
cost
is
there's
no
trigger
finger
to
those
they're
viewed
as
except
essential
expenditure,
and
they
won't
be
challenged
by
creditors.
P
The
challenge
would
be
around
the
more
discretionary
areas
of
expenditure,
so
I
think
that
it's
very
positive
thing
for
clients
who
don't
have
to
then
have
the
spending
garland
pursued
against
things
like
their
bus
fare.
Or
what
have
you
and
the
final
point
on
public
sector
creditors
I
can
only
really
reflect
on
the
experience
we've
seen
down
in
England
and
Wales
Sanna
furniture
statements
been
in
operation
since
the
1st
of
March
2017
there
and
we've
had
just
over
100
local
authorities
in
England
Wales,
who
have
signed
up
to
express
an
interest
and
I'm.
P
Just
clear
with
the
committee
is
expressed
an
interest
in
using
the
standard
financial
statement
as
their
approach
to
assessing
affordability
and
a
number
of
those
have
actually
now
implemented
it.
The
rest
are
investigating
that,
and
we
also
see
it
on
a
cabinet
office,
fairness
group,
which
has
the
likes
of
DWP
and
HMRC
upon
it,
and
that
is
a
key
topic
of
the
agenda
at
the
minute,
actually
having
a
consistent
approach
to
public
set
the
debts
as
well,
actually
so
I
very
encouraged,
actually
that
the
moment'
and
the
SF
s
is
building
and
I
would
expect.
M
And
my
final
questions:
convener
is
it's
a
panel
confident
that
the
SAFS
will
be
accepted
by
UK
government
bodies
and
if,
alternatively,
if
the
common
financial
statement
was
to
be
continued
in
Scotland,
who
would
maintain
it
and
whether
that's
common
financial
statement
or
SF
s?
What
are
the
issues
around
any
assessments?
Course?
Bureaucracy
for
those
are
providing
advice
and
I
may
just
start
of.
P
Course,
there's
a
few
examples
where
the
UK
government
have
already
accepted
the
use
of
s
FS.
You
know
one
example
would
be
in
some
service
in
England
and
way
always
use
it
to
assess
bankruptcy
already
in
health
dawn
since
April
2017
they're
very
positive
about
the
standard
financial
statement.
It's
in
the
pre
action
protocol
in
the
court
system
down
south
as
well
and
I
should
also
mention.
P
Yesterday
with,
along
with
the
budget
papers,
the
the
Treasury
published
plans
for
a
century
debt
management
plan
which
would
be
similar
to
the
des
or
peer
in
Scotland,
and
they
reference
use
of
standard
financial
statement
in
that.
So
I
have
no
doubt
that
it
is
well
supported
more
broadly
in
the
UK,
certainly
and
sorry
I
forgot.
What
the
the
second
question
was.
It.
P
Currently,
it's
maintained
by
a
charity
called
the
Money
Advice
Trust
this
the
common
financial
statement.
Now
they
have
indicated
that
they
intend
to
cease
the
common
financial
statement.
If
everyone
goes
on
to
SSS,
of
course,
I
believe
they'd
be
seeking
funding
to
do
that.
If
they
want
to
continue
it
the
minute
we
will
fund
the
standard
financial
statement,
I'll
be
of
no
cost
to
anyone
bought
ourselves.
Okay,.
O
We
are
I
would
tend
to
agree
in
terms
of
the
adoption
of
SF
s
by
by
you
key
government
departments,
I
think
it
is
broadly
well
supported,
etc.
I
think
question
of
maintenance
of
common
financial
statement,
if
that
was
maintained
within
within
Scotland
I,
think
we
need
to
understand
the
the
basics
in
behind
it.
I
guess
is
you
know.
Fundamentally,
it
is
a
model
where
categories
of
expenditure
are
allocated
against
a
model.
O
Essentially,
those
figures
are
taken
from
ons
starts
at
the
moment:
household
expenditure,
so
in
terms
of
the
actual
maintenance,
I
I,
don't
think
that's
a
huge
deal
in
terms
of
you
know
just
taking
whatever
way.
Next
figures
are
there
and
putting
it
into
the
appropriate
format,
because
it's
a
formatting
issue
rather
than
anything
else-
and
you
know
SF
s
and
CFS
Aussies
is
using
the
same
things,
but
just
with
categories
of
expenditure
in
slightly
different
areas,
so
I
I,
don't
really
see.
N
So
perhaps
somebody
completely
independent,
who,
as
david
says
to
some
of
the
wider
economic
figures
and
put
that
into
the
model,
perhaps
reserved
volunteer
institute,
was
a
kind
of
an
obvious
one
that
I
thought
or
a
different
government
agency
or
department,
maybe
that
you
can
all
make
a
date
to
that
for
an
example.
So
it
would
be
idly
of
a
separation
between
the
setting
of
the
standard
and
in
the
implementation
that
crossed
my
mind,
that
that
would
be
very
important.
Okay,.
K
Nothing
nothing
much
to
add
from
what
the
panel
said
already
in
terms
of
who
would
mean
to
unit.
But
what
would
the
emphasizes
that?
A
few
after
spending
things
are
broadly
in
line
between
CFS
and
SF
fest,
and
then
what
we've
got
there
really
I.
Just
think
some
of
that
too
much
deference,
but
I
feel
possibly
added
that
those
certain
drawbacks
and
falls
within
SF
s.
K
Then
you'll
also
find
that
within
the
CFS,
for
example,
those
no
transparency
under
either
option
and
the
relationship
between
the
client,
the
creditors
and
advisors,
the
clients,
the
the
only
person
that
hasn't
had
accessed
through
spending
gateways.
I,
don't
know
if
the
panel,
if
the
collective
sort
of
had
access
to
the
getting
things.
But
what
preventing
members
of
the
public
from
seeing
these
gatherings
does
for
me
helps
contribute
to
that
notion
and
that
mass
conception
that
people
in
that
somehow
can't
be
thrust
either
after
they
could
access
these
guidelines
that
are
somehow
gonna
game.
K
The
system,
as
Alan
said
already,
building
that
hasn't
acclaim
and
we
need
to
change
a
lot
of
the
misconceptions.
Many
people
in
there
we're
also
concerned
under
both
options.
Dozen
audio
contention
see,
when
is
ten
percent.
A
disposable
income
capped
at
twenty
percent.
Now,
if
you're
paying
fifty
pounds
per
month
towards
your
debt,
then
you
get
five
pounds:
disposal
wangkong
contingency,
slack,
they'll,
deploy
right,
it's
just
not
sufficient
to
deal
with
unexpected
expenditure.
K
I
know
that
we've
mentioned
I
only
mentioned
living
standards
and
David
mentioned
is
where
the
methodology
that
underpins
both
CFS
and
SF
s.
It's
based
on
the
spending
patterns
within
the
bottom
20%
Harry
sauce
in
loving
course,
and
food
softly
Africa
made
the
case
that
a
few
based
on
what
the
bottom
20%
of
spending,
then
your
based
on
people
who
are
spending
what
they
have
rather
than
what
they
need,
and
that
seems
to
me
to
be
their
own
starting
point.
K
M
A
M
E
Know
just
on
that
last
point,
whether
we
couldn't
as
a
committee
request
sight
of
that
guidance
I
think
it
would
be
useful
in
our
deliberations
and
I
wonder
whether
I
could
be
slightly
cheeky,
because
David
spoke
about
his
network
of
Money
Advice
advisors.
When
did
you
each
of
you
in
turn
last
provide
face
to
face
advice
to
a
debtor
using
one
of
these
common
financial
tools?
David,
we
start
with
you.
I
am.
K
Not,
a
I've
never
been
a
front.
Limon
advisor
I
was
a
pointed
as
a
police
officer
at
Money,
Advice
Scotland,
but
I'm
very
much.
Somebody
who
always
thought
that
police
officers
should
remain
in
office
and
have
the
head
stock
in
focusing
legislation,
a
money,
vase
Scotland.
We
walked
to
the
maxim
that
after
yourself,
something
without
evidence,
it
can
be
this
mess
without
evidence.
So
we
put
evidence
at
the
very
heart
of
it
of
all
that
we
do.
Our
analysis
of
the
CF
s
and
s
FS
has
been
based
on
villa
course.
K
Engagement
with
our
members,
we've
had
three
consultation
events:
we've
had
different
engagements
throughout
the
country
in
Glasgow
and
Robert
Dean.
We
also
went
through
the
rather
laborious
tasks
of
lane
family,
taking
CFS
financial
statements
and
transposing
it
under
the
new
standards.
Financial
statements
or
work
should
absolutely
correct
to
say
that
I
don't
have
friendly
advice,
experience
the
level
of
engagement
that
we've
had
before
members
I
hope
for
some
way
to
make
up
for.
E
N
O
O
E
P
E
E
E
The
question
is
which
one
and
how
does
it
work
and
whose
interest
is
in
so
you
know,
I,
just
I
wanted
to
be
a
bit
cheeky
and
ask
that
question
and
let
me
come
on
to
something
more
substantive
and
clearly
conflicting
views
between
the
accountant
in
bankruptcy
and
at
least
money
advice
Scotland,
if,
if
not
others
as
to
whether
the
use
of
the
standard
financial
statement
will
result
in
more
or
fewer
trigger
figure
breaches,
what
are
your
views
and
I'll
come
to
David
Menzies?
First,
seeing
it
was
only
last
week.
O
I
mean
without
I,
guess
prejudging
what
David
might
say:
I
don't
think.
Actually
there
is
a
huge
difference
in
terms
of
the
IV
and
money
advice,
Scotland's
view
of
I
think
there
is
commonality
in
in
terms
of
the
view
that
there
will
be
increased,
trigger
finger
breaches
using
the
s.
Fs
I.
Think.
The
question
is
by
how
much
and
how
many
okay
so
I'm
sure
they
will
talk
about
this
in
a
bit
more
detail.
O
O
The
initial
comparative
survey
that
Money
Advice
Scotland
carried
out,
but
that
percentage
was
about
40%.
Okay,
since
the
figures
were
were
operated.
The
Money
Advice
service,
Rees,
established
that
evidence
and
that
came
out
about
4%
of
bankruptcies
would
result
in
increased
rigor
figure,
brie,
cheese,
so
I
think
there's
commonality
across
the
board
saying
the
Roby
additional
trigger
for
breaches,
the
Roby
additional
effort
into
requirements
and
your
thought
that
that's
just
the
way
it
is.
K
Think
as
important
to
stress
that
the
initial
vib
consultation
took
place,
I
think
back
in
a
toolbox
last
year,
or
at
least
cause
then
at
full
well
last
year
an
argument
I,
don't
check
out
forgave
things
is
certainly
moved
on
a
lot
since,
in
fact,
since
then
has
been
to
set
up
ratings
to
the
spending
gave
things
with
nsfs
since
then,
and
I
think
a
huge
America
latest
you
to
Caligula
scoids
a
Money
Advice
service.
For
that
we
were,
we
were
the
forefront,
a
reason.
K
These
concerns
there
was
a
response,
those
concerns
and
certainly
I
got
categories.
The
Gatling
is
increased
by
more
than
hundred
percent
as
both
northern,
however,
that
another
I
think
was
it
the
the
last
operating
in
2017.
So
the
SF
air
scalings
have
increased.
The
CFS
guidelines
have
come
down
slightly
and
and
that's
why
we've
got
this
picture
as
much
as
anything
else
or
I
said
I
gave
lanes,
that's
brought
them
all
equivalent
when
we
asked
manav
a
trust
why
the
CFS
gave
wings
had
come
down,
which
seems
somewhat
perplexing.
K
I
mean
your
household
bills
haven't
come
down
and
the
last
yields
will
have
they
what
they
said
and
again
it
comes
back
to
the
methodology.
People
in
that
bottom
income
quintile
were
registered,
I
spending
less,
they
were
spending
less
because
they
had
less
because
they
had
less
the
CFS
kaitlin's
came
down
accordingly.
No
that's
another
one
of
the
the
drawbacks
that
we
see
in
the
current
methodology
and
again
I'd
emphasize
that's
what
they
were
using
CFS
or
whether
we're
using
SFX.
N
Could
I
just
add
actually,
who
in
CFS
came
in
that
the
number
of
individuals
making
contributions
plummeted
so
between
fifty
and
seventy
five
percent
of
data
in
our
insolvency
solution
at
that
time
went
from
paying
a
contribution
to
no
contribution.
So
the
fact
that
we're
now
going
back
to
just
four
percent,
arguably
or
four
to
twelve
percent
McCain
had
a
slightly
increased
contribution.
I'm
I
would
just
like
to
put
that
in
context
and.
P
Getting
praise
there
well,
thank
you
David,
particularly
for
that
I,
don't
like
to
add
to
what
David
said.
The
only
thing
I
would
mention
is
it's
very
difficult
compared
precisely
going
financial
statement
to
standard
financial
statement,
the
best
that
what
I
see
is
most
reliable
is
what's
happened
where
it's
been
live
in
England
and
Wales,
and
none
of
the
providers
who
have
using
it
south-of-the-border
have
reported
any
problems
and
any
particularly
increase
in
trigger-finger
branches.
Okay,.
P
Happy
to
and
set
that
one
and
know
they're
spending
guidelines
that
are
attached
to
three
areas
of
expenditure,
a
uk-wide
spending
guidelines,
and
it
it's
all
tied
up
with
the
the
standardization
of
this
format
that
it
would
be
used
UK
wide.
The
key
thing
to
stress
on
that
is
that
they
said
within
the
guidelines
and
guidance
for
s
FS
that
clearly
there'll
be
areas
where
take
very
rural
areas,
for
example,
where
there
may
be
higher
expenditure,
we're
spending
guys
have
reached.
K
That
we've
seen
the
rest,
particularly
in
response
to
the
additional
cost
of
lebanon,
remote
and
rural
Scotland
and
well.
Ivan,
said
that
and
I
know
cremates.
That's
about
transport,
of
course,
and
energy
costs,
though
not
sure
I
got
the
categories,
but
the
arc
article
is
a
pure
submitting
started
to
the
application
to
AIB
have
to
be
evidence
in
every
case
whether
or
not
that
spending
skin
settled
excess
of
no
and
I
I.
Think
we
need
to
look
at
the
rate
of
context.
K
The
money
base
X
at
the
moment,
investment
from
local
authorities
and
one
advice
services
is
dropped
by
forty
five
percent
in
the
last
two
years.
What
we
need
is
money
advisors
on
the
front
line
advising
clients
we
don't
need
them
chase,
not
fuel
bills.
We
don't
need
them
chasing
up
a
boss
techies
this
summer
as
part
of
the
application.
So
is.
O
Purely
in
terms
of
comparison
between
the
CFS
and
the
SFA's,
it
probably
doesn't
make
any
difference.
Both
are
done
on
the
same
figures,
essentially
those
same
source
figures.
There
is
no
regional
variation
in
that,
but
both
of
them
allow
a
degree
of
flexibility
or
rationalization
for
individual
circumstances,
but
I
think
that
then
comes
back
to
the
you
know
the
original
principle,
which
is
actually
going
to
one
day
advisor.
You
should
get
the
same
result
as
going
to
any
other
one
and
I'm,
not
convinced
that
under
either
CFS
or
the
FSS.
O
You
actually
get
that
because
some
people
do
allow
something
you
know
whether
it
be
cigarettes
or
the
degree
of
travel.
You
know
that
rationale
around
well.
Actually,
how
much
is
too
much
travel
to
go
and
visit
your
daughter
or
whatever
that
doesn't
get
away
from
either
the
CFS
or
the
SFA's?
Not
judgment
is
still
built
in
as
part
of
those.
N
What
I
would
just
add
to
that
is
that
the
the
point
isn't
necessarily
which
to
use
it's,
how
we
implement
it,
and
there
is
a
there's-
definitely
I-
think
we're
all
in
agreement.
A
wider
discussion
about
the
level
of
comprehension
and
evidential
requirements
that
go
into
supporting
that,
both
in
terms
of
a
cost
both
to
the
Money
Advice
sector,
to
the
insult
and
say
profession,
and
to
the
level
of
evidence
that
the
accountant
in
bankruptcy
who
oversees
the
implementation
of
this
I
am,
and
certainly
from
a
sequestration
point
of
view,
say
it's
the
contributions.
N
I
K
O
I
think
is
sort
of
indicated
already.
There
is
a
large
evidential
requirement,
which
is
really
that
burden
as
a
result
of
the
operation.
The
way
they
came
to
bankruptcy,
operate
it
and
require
evidence.
Those
were
concerns.
You
know
the
the
are
in
place,
whether
it
is
the
common
financial
statement
or
the
fitnah
or
the
sounder
financial
statement.
O
You
know
we
we've
done
based
on
the
analysis
carried
out
by
the
IB
and
one
advice:
Scotland,
we
are
conservatively
estimating
the
costs
to
the
UK
economy
or
the
economy
in
Scotland.
I
guess
is
somewhere
between
one
hundred
and
fifty
five
thousand
and
four
hundred
and
fifty
thousand
per
year
depended
upon
which
which
range
of
breaches
is
the
the
the
the
the
you're
looking
at.
So
the
there
undoubtedly
is
a
cost
to
this
is.
I
O
Money
Advice
service
provide
an
Excel
template
spreadsheet,
so
some
places
will
use
that
they're
going
to
in
bankruptcy
have
built
into
their
systems
into
into
basis
the
the
common
financial
statement
which
will
have
to
be
updated.
So
undoubtedly
those
IT
costs
there.
Some
other
practices,
step
change
and
such
like
again.
They'll
need
to
invest
in
IT
changes
as
well
yep.
If.
O
N
Pick
up
on
the
insolvency
point
being
an
insolvency
practitioner
and
keeping
abreast
of
the
million
changes
we
have
the
new
insolvency
Scotland
drills
coming,
for
example,
we
have
to
just
absorb
that
cost
as
a
cost
of
doing
business
and
I
would
suggest
that
most
of
the
IPS
have
already
are
on
board
with
us.
And,
yes,
there's
lots
of
things.
We
can
do
to
talk
to
Elliot
Lee,
tae
IP
systems,
but
they're,
not
a
significant
cost
to
the
IP
community
and.
P
To
add
to
that
I
disagree
with
what
David
is
saying:
I,
don't
believe
there
is
any
evidence,
that'll
be
additional
burden
between
CFS
and
the
common
financial
statement
which
is
currently
used.
The
spending
guidelines
are
broadly
similar,
there's
actually
one
less
expenditure
category
that's
covered
by
a
spending
guideline,
so
I,
don't
think
there'll
be
any
increase
on
that
front.
There
add
to
what
we
provide
for
kind
of
the
system
stuff.
There
is
an
excel
tool.
P
J
P
Us
that's
right,
we're
an
independent
body
settled
by
government.
It's
a
technical
way
of
putting
it
I.
Think
a
quango
would
be
the
phrase
that's
that
used,
but
our
statutory
objective
is
to
improve
the
quality,
consistency
and
availability
of
the
advice
in
the
UK
and
the
reason
why
I
think
we're
the
right
people
to
be
developing
at
all
like
this?
Is
we
have
none
of
the
axes
to
grind
around
the?
What
the
contribution
made?
We
want
the
ability
of
a
sector
that
works
well
for
both
creditors
and
the
advice
agencies.
J
P
Statement
it
was,
we
were
established
in
2012
and
we
did
a
consultation
on
what
would
be
the
right
things
for
us
to
look
at
in
the
debt
advice
set.
So
it's
kind
of
set
to
why
initiatives
that
will
help.
Do
those
things
improve
the
quality,
consistency
and
availability
of
debt
advice
in
the
UK
and
one
of
the
strongest
things
that
came
back
amongst
other
things,
was
to
have
a
standard
approach
to
financial
statements
across
the
country
because,
as
I
mentioned
at
the
top
there's
a
lot
of
disadvantages
to
having
various
different
approaches
to
that.
J
You're,
seeing
you're
independent
from
government
I
suppose,
because
one
of
our
concerns
might
be
that
going
forward,
while
I
might
be
comfortable
with
where
we
are
at
the
moment,
and
it
seems
to
be.
The
two
models
are
not
that
different
in
you
know.
Could
there
be
political
pressure
put
on
your
agency
and
the
future
either
to
see
squeezed
down
in
what
debt
are
allowed
to
keep
or
inflate
what
debtors
are
allowed
to
keep
that
kind
of
area
is?
Are
there
clear
rules
around
us.
P
And
well,
the
methodology
itself
that's
used
to
find
the
the
guidelines
that
is
is
set.
It
is
written
only
it's
in
stone,
it's
a
process,
that's
that's
wrong!
Every
year
by
our
statistician
and
we
produce
all
that
calculations.
So
it's
not.
It
wouldn't
be
easy
to
go
and
change
the
methodology.
You
know
secretly.
We
have
a
Governance
Committee,
which
has
got
people
like
sittings
of
ice
and
by
Scotland
when
he
advise
Scotland
most
advise
friars
in
the
UK
number
of
creditors
and
the
AIB,
who
would
have
a
say
in
what
that
methodology
is.
P
So
we
would
like
to
say
he
and
the
our
position
is.
This
is
a
collaborative
project.
The
standard
financial
statement
is
really
the
sector's
tool.
Noora
hours
and
those
decisions
are
done
in
consultation
with
practitioners
really,
rather
than
we
come
up
with
durmand
and
roll
them
out.
It
is
done
very
collaboratively
and
I
must
just
popped
on
record
how
grateful
we
are
to
AIB,
who
have
been
very
collaborative
in
this
process
and
shed
a
lot
of
learnings
with
us
about
the
common
financial
tool.
That's
been
here
for
since
2015,
okay,.
J
K
K
I
think
you
need
any
change
to
that
methodology.
As
Craig
said,
this
is
what
I
suppose
that
there's
like
governance
group
say
up
there.
The
covers
a
range
of
bodies.
Of
course
they
said
if
you
get
another
hand
and
you
quite
like
the
notion
of
the
view
and
other
ways
that
we
may
do
this,
then
there's
a
low
probability
of
that,
so
that
that
would
be
another
side
of
you.
Your
question,
okay,.
O
I
think
generally
in
terms
of
how
the
the
tool
is
put
together
and
working
absolutely
I've
got
no
no
concerns
around
that
I.
Think
I
think.
The
concerns
that
we
would
have
in
relation
to
the
regulations
is
really
the
it's
more
a
principle
based
type
thing
really
where
the
the
control
of
that
is
not
within
the
control
of
legislators
or
within
Scottish
Parliament.
So
really
around
the
the
system
of
insolvency
practitioner
regulation,
authorization
monitoring,
some
of
those
aspects
are
not
sufficiently
well
protected.
I
would
suggest
within
within
the
regulations.
O
What
the
code
of
conduct
this
that's
available
for
the
s
FS,
for
instance,
dictates
or
allows
the
governance
group
to
decide
who
can
and
cannot
use
the
S
FS.
But
then
we
have
within
legislation
our
requirements
in.
While
you
have
to
use
this
so
or
you
could
potentially
have
the
the
possibility.
I
guess
where
the
governance
group
is
saying,
this
forum
is
not
applying
the
the
the
procedures
correct.
O
I
think
you
know
it
could
it
could
easily
have
been
resolved,
I
think
essentially
by
the
licensing
being
done
direct
to
the
to
the
IP
of
the
Scottish
government
and
then
just
been
brought
in
that
way.
But
it's
a
it's
a
confused
bit
of
legislation
in
that
way,
yep
you
could
ask
most
of
someone's
to
comment.
P
Very
happy
to,
of
course,
I
think
what
David
is
saying
is
technically
accurate,
I
think
in
practice.
The
likelihood
of
that
is
very
slim,
because
we've
designed
the
SSS
in
collaboration
with
the
AIB
actually
and
I
believe
the
principles
that
we
set
out
in
how
you
use
the
standard
financial
statement
are
the
same
as
the
AIB
s,
so
the
chances
are
they're,
being
a
disagreement
are
very
slim
and
that
governance
group
that
David
has
touched
on
has
got
AIB
on
it.
P
Actually,
I
would
never
foresee
a
day
of
us
withdrawing
a
license
without
consultation
with
the
AIB
just
to
give
some
additional
comforts
as
festive
in
live
since
the
1st
of
April
2017
and
as
yet,
we've
had
no
reason
to
remove
anyone's
license.
So
I
think
that
the
likelihood
of
that
is
very
small.
Most
McLean.
N
That
provision
exists
already
with
CFT,
where
you
have
to
be
licensed
by
the
Money
Advice
Trust
to
use
it
and
when
we're
talking
about
license,
they
really
just
mean
registration,
so
they
know
who's
using
it
and
and
whatever
and
we've
had
no
incidents
that
severely.
Certainly
any
insolvency
practitioner
having
their
license
to
use
a
CFD
was
drawn
in
that
time.
Okay,.
G
G
Is
that
a
concern,
therefore,
that
the
standard
financial
statement
is
not
taking
account
of
what
some
critics
would
regard
as
a
reasonable
standard
of
living,
as
opposed
to
the
standard
of
living
of
the
lowest
income?
Households
who,
by
definition,
are
probably
spending
less
than
they
should
be
in
certain
areas?.
P
I
don't
want
to
get
in
the
jargon
he,
but
actually
the
expenditure
level
was
at
that
lowest
quintile
users
action.
The
second
would
be
the
second
quintile
of
expenditure,
so
that
gave
us
some
real
reassurance
that
is
broadly
aligned,
but
the
minimum
could
standard
that
the
Joseph
Rowntree
Foundation
do
and
we've
committed
to
running
that
exercise
regularly
to
see
if
they
broadly
stay
aligned
or
if
they
diverge
incan.
If
they
start
to
diverge,
you
know
we'll
look
into
that.
So.
K
K
What
to
be
done
between
where
the
checkered
flag
was
set
and
what
was
understood
as
a
socially
acceptable
in
standards
so
really
pleased
to
see
that
were
kind
of
taking
the
only
household
tight
within
that
research
and
the
committee
made
bench
race
and
that
research,
incidentally,
the
my
household
tape
that
had
a
better
view
under
minimum
comes
down
with
a
few
like
the
none
of
the
trade
off
figures
was
for
a
single
person.
No
every
other
household
same
tape
fail
slightly
below
the
minimum
income
standard.
K
K
It
looks
broadly
length
on
paper,
but
in
practice,
when
you
think
of
what
that
host
thoughts
for
seeking
week
to
week
through
a
payment
agreement
that
made
last
five
six
seven
eight
nine
ten
years,
no
I
think
it's
easy
to
view
a
financial
statement
as
something
over
so
abstract
concept.
It's
an
uncommon,
expensive
form,
essentially
with
the
certain
gain
things
when
spending,
of
course,
as
that,
but
it
was
so
much
more
than
that
effectively
said
so.
K
I
stand
that
I
living
for
a
household
for
a
client
over
the
period
of
the
reaping
of
this
we've
been
consistent.
It's
a
drawback
of
CFS
and
SF
s
that
we
don't
have
a
way
of
checking
whether
or
not
that
payment
agreement
we've
something
worth
a
social
except
to
eleven
standard.
That's
something
that
we've
advocated,
that
does
not
other
support
for
I
would
rephrase
up.
K
There
was
no
support
for
from
the
SF
s
governance
group,
but
again
it's
an
example
of
something
that
if
we
had
controlled
us
ourselves,
that's
something
that
we
could
aspire
to
I.
Don't
know
why
you
wouldn't
want
to
know
that
the
payment
agreement
that
you
set
up
will
that
leave
somebody
in
terms
of
social
accept
all
standard,
loving.
G
Okay,
this
is
a
regulations
which
Parliament
will
decide
whether
to
approve
or
not.
We
can't
amend
them,
of
course,
and
it's
a
take-it-or-leave-it
I
was
intrigued
at
the
I
guess
say
in
your
evidence,
we
would
strongly
encourage
AIB
and
Scottish
government
to
defer
any
decision
on
the
use
of
CFS
or
SF
s
and
instead
to
make
an
assessment
of
the
policy
effectiveness
behind
the
CFT.
Is
it
your
view,
therefore,
that
we
should
not
pass
these
regulations
I.
O
G
G
O
Would
suggest
that
the
the
under
the
the
underlying
rationale
behind
these
regulations
is
simply
because
on
a
uk-wide
basis,
there
is
no
the
standard
financial
statement.
There
is
the
withdrawal
off
the
the
CF
s
being
maintained
and
those
two
items
they
are
are
driving
the
change
in
in
regulations
not
actually
whether
those
are
policy
need
to
change
the
regulations.
N
Perhaps
a
tendency
for
the
the
Parliament
for
the
government
to
to
look
at
this
Justin.
Well,
what
can
we
fix?
We
can
fix
of
bankruptcy
law.
We
can
bring
in
s
FS
for
CFS.
There
are
whole
other
policy
issues
that
set
behind
this
about
minimum
wage,
about
living
wage
about
a
what
is
our
socially
accepted,
minimal
level
of
income,
and
these
regulations
are
not
going
to
fix
that
and
it's
arguably
and
that
there's
all
sorts
of
other
things.
N
You
know
we've
long
called
in
the
insolvency
profession
in
Scotland,
for
a
root
and
branch
of
U,
of
whether
the
family
home,
for
example,
should
be
included
in
a
bankruptcy
or
upset
to
trust.
Eed
know
that
we
can
have
that
to
be
that
that
has
to
be
said
against
a
whole
discussion,
a
wider
discussion
about
housing
policy
in
the
country,
for
example,
and
therefore
I
think,
there's
a
tendency
to
think
that
oh
well,
we'll
bring
an
SFA
spur
and
that's
gonna
fix
all
of
these
other
issues.
It
won't
s.
N
G
K
K
We
also
welcome
a
review
of
potential
tenders,
but
I
think
one
thing
that
that
we
need
to
do
as
a
sector
a
whole
lot
better,
moving
that
this
process
is
engaged
with
a
range
of
ips,
a
range
of
money,
advisors,
arranger
creditors,
but
we
haven't
really
held
from
people
and
their
people
who
heard,
and
these
plans
and
one
of
the
most
encouraging
things
I've
seen
from
Scottish
government
and
recent
years
was
establishment
of
experience
panels
with
the
view
that
who
better
to
help
shape
a
new
system
than
people
worth
experiencing.
Often
quite
important.
G
O
I
could
just
reflect
a
guess
on
some
other
countries,
experience
where
they
don't
use
this
particular
method.
So
if
you,
particularly
at
Canada
or
Australia,
for
instance,
the
way
the
SS
data
of
contributions
or
surplus
income
into
that
is
that
they
will
take
the
income
level.
They've
got
a
number
of
bands
which
take
into
account
how
many
people
are
in
the
household,
dependencies,
etc,
and
they
say
an
element
of
income
which
is
you're
out
with
the
scope
of
data
contributions,
and
then
they
say
a
percentage
above
that.
O
So
it's
a
very
straightforward
system
really
easy
to
understand.
It
doesn't
have
costs
to
maintain
you
know
it
doesn't
have
a
large
administrative
burden
and
your
VAT
could
be
used
as
a
model
I
would
suggest
within
within
Scotland.
I
wouldn't
suggest
exactly
the
same,
because
again,
I
think
that
there
are
some
disadvantages,
that
it
doesn't
particularly
take.
O
A
kind
of
you
know
people
with
additional
support
needs
or
that
sort
of
thing
where
there
might
be
levels
of
expenditure
required
there,
but
I
think
that
sort
of
system,
with
our
an
adapted
percentage
for
Scotland,
perhaps
with
an
additional
four
Lord
percentage
for
those
additional
needs
of
people,
could
could
work
effectively
within
Scotland.
So.
G
O
By
simply
reducing
the
costs
of
administering
the
calculation
right,
that's
help
yeah.
So
it's
like
sorry,
yes,
so
just
to
clarify
it
written
result
necessarily
in
increased
state
of
contributions
resulting
in
increased
Decatur's.
They
would
lower
the
cost
of
administration.
Okay,
that's
help
yeah!
Thank
you.
Yeah.
K
About
tell
thoses
this
David
I'll
inject
a
set
percentage
contribution
of
f
consistencies
object,
Ovilus
policy
that
the
nut
seems
a
really
consistent
approach.
You
could
join
the
Joseph
Rowntree
foundations,
man,
a
man
comes
standard.
If
you
wanted
to
search
trade,
no
Ivan
standards,
the
bit
the
Heartless
process,
you
could
apply
the
s
FS
without
sparing
the
game
things
as
a
format
itself.
It's
absolutely
fine.
It
looks
good
walks.
K
Well,
they
can
say,
as
before,
health
comes
from
the
Spain,
the
game,
things
so
and
I,
don't
say
that
to
dissing
facetious,
but
we
saw
in
the
AI
piece
consultation
that
spending
guidelines
shouldn't
influence
contributions.
Well,
if
they
shouldn't
and
points
what
somebody's
pain
towards
are
there,
then
why
have
them
at
all?
So
those
does
not
let
those
tariffs
I
feel
that
we
could
be
examining.
A
P
You
and
I
just
want
to
give
some
extra
reassurance
to
the
committee
that
the
standard
financial
statement
has
been.
You
know
some
years
in
the
making
actually
in
its
look
to
build
on
the
good
practice,
it's
already
out
there.
So
it's
it's
taken.
What's
worked
in
the
con
financial
statement,
it's
also
taken.
P
What's
worked
in
the
step,
change
approach
which
they
use
and
various
others
that
are
used
in
in
public
Proteus
to
affordability,
assessments
and
it
has
been
tested
with
the
Money
Advice
community,
quite
good
length,
so
I'm
confident
this
is
the
current
best
practice
available
just
to
touch
on
the
point
around
spending
guidelines.
I
just
think
it's
worth
touching
on.
What's
in
our
guidance
for
using
the
standard
financial
statement,
which
is,
they
are
exactly
their
guidelines,
they
are
not
allowances
to
be
capping.
People
suspended
Charette,
it's
become
one
David's
point.
P
Finally,
I
won't
take
up
too
much
the
committee's
time
on
this,
the
ons
survey,
which
is
the
basis
of
the
methodology.
Our
assessment
is,
that
is
the
most
robust
set
of
data
out
there
at
the
moment
for
building
a
set
of
lines.
Like
this,
we
looked
at
the
Joseph
Rowntree
approaching.
We
worked
very
well
with
the
Joseph
Rowntree
Foundation
actually,
but
their
sample
size
is
quite
small
and
the
the
way
they
update
it
annually
is
not
across
every
household
type.
P
P
Not
as
yet
because
we
have
rolled
it
out
only
a
year
and
a
half
ago,
but
we
have
a
plan
to
evaluate
both
the
impact
on
the
client
and
the
impact
on
their
advisor
and
the
impact
on
the
creditor,
and
that's
when
we
reach
a
certain
scale,
we're
hoping
that
Scotland
will
be
on
board
when
we
do
that,
so
we
can
test
the
the
impact
of
its
new
policy,
so
we
will
evaluate
it.
We
always
do
okay,.