Official Report 128KB pdf
We thought that the title of the regulations was quite a mouthful—to use strictly legal terms. We asked last week whether some of the words in the title were unnecessary. The Executive responded that it wanted to draw attention to the difference between mortgage-style student loans and the student loans to which the regulations refer.
This is one of the issues that the committee will continue to examine. We have said that the titles of instruments should make clear to ordinary citizens exactly what they are about. The Executive has provided an explanation, which can be justified, as to how the title has been arrived at. There must be best practice—as we have said on other issues that we have raised with the Executive, such as consolidation—in producing titles that are as snappy as possible and convey what is in the instrument without being such a mouthful.
The Executive must decide whether the title can be changed before it comes to the fifth consolidation, which I am assured is the point at which it would consider changing such things. We will draw the point to its attention.
I am not sure whether it is worth drawing to the attention of the lead committee.
It is the principle. We might want to say to the Executive that it should consider the length of titles.
This is not so much an issue for the lead committee; it is a general point for the Executive. It would be best raised at informal chats with the Executive.
It is a fair point to raise with the Executive.
The lead committee will not be able to do anything about the instrument. It is worth raising the general issue.
Should we write an informal letter to the Executive to say that the problem continues to arise?
Previously, the committee has had informal chats with the Executive on drafting issues. The issue could be discussed at that level.
Should we discuss it in that way rather than by letter?
We have put our comments on record. Anyone who wants to know our views can read the Official Report.
If the situation does not improve, we can have a chat with the Executive.
I understand why some regulations have enormous titles, but they are off-putting for members of the public who want to get information. It is fine for lawyers or people like ourselves who are put in a situation where we have to deal with it, but it is grim for people who want to know what to do and where to do it.
We will raise the matter informally.