MSE reports and consultation responses
This page contains the MSE Campaigns team’s reports and consultation responses.
We’ll update this page regularly as we publish new work.
Our campaigning reports draw attention to particular consumer problems, provide new evidence about the issue, and make recommendations for change. These reports will usually be directed to the Government department or the regulator responsible for making improvements to the system. Reports are not the end of our campaigning work on an issue though, as we will then turn our attention to making sure that they lead to positive changes being made for consumers.
Explore our more recent reports below.
This report calls for reform of APRs for credit cards and personal loans, and greater transparency of the credit advertising space. Using research commissioned by MSE and undertaken by YouGov, we found that the current system damages consumers’ financial and emotional wellbeing. The report makes a number of recommendations, such as:
- Replace representative APRs with typical APRs. This means at least 66% (currently 51%) of successful applicants would be offered the advertised rate – though even more is better.
- Cap the difference between the typical and maximum APR.
- Mandate firms to disclose the average proportion of successful applicants who don’t get the advertised APR, and by how much.
- Apply the improved APR rule to advertised 0% deal lengths for credit cards too. This would mean at least 66% of those accepted get the advertised 0% length. Currently there isn’t a rule on this. (It should also apply to other risk-based pricing models.)
- Consider mandatory quotation searches (or ‘soft’ credit searches) for credit card and personal loan applications. Or at the very least, before application, firms should communicate prominently the rate range for those not accepted at the advertised rate.
Our report was welcomed by the Chancellor, Rishi Sunak MP. In response to the report, he asked the regulator, the FCA, to investigate. For more information, read our news story.
Read the full report: It's time for a 'Typical' solution to interest rate shock
MSE commissioned LSE London to research and write this report, which was funded by Martin Lewis. This important work highlighted the urgent need to unlock 250,000 mortgage prisoners.
LSE London recommended 8 potential solutions to free mortgage prisoners, and crucially, identified that only the Government could act to free them. The recommendations include:
- Interest-free Government equity loans – which, similar to the Help to Buy scheme for first-time buyers, would bring down some prisoners’ loan-to-value ratios so they can remortgage.
- Remove ‘Together’ loans as an obstacle – by decoupling the secured and unsecured elements of this former Northern Rock product (2), taken out by many mortgage prisoners.
- Mortgage rescue – which would allow those whose mortgages are financially unsustainable to remain in their homes as tenants, while the property is sold to housing associations with a buy-back option later.
- Bringing all owners of ‘closed books’ within the FCA’s oversight – similar to measures in Ireland, this would bring owners of ‘closed books’ within the FCA’s regulatory perimeter.
For the full analysis and recommendations, read LSE London's full report: Releasing the mortgage prisoners.
Also see MSE's news story on the report's publication: Only the Government can release the 250,000 mortgage prisoners it's failed - and coronavirus is a tipping point, so not acting now could devastate lives.
In 2020, in the early months of the pandemic, the MSE Campaigns team worked to understand the issues that were facing consumers, and to report these to Government, Parliament and regulators. This was to help inform the policies across larges swathes of personal finance that were being rewritten at record speed.
Find out more about how we did this, and some of the changes that happened.
Following the recommendations MSE set out in its 2017 report, Sharper teeth, we conducted further research into the 8-week rule — the time a consumer often has to wait before they can take their complaint to an ombudsman.
We commissioned YouGov to conduct primary online research, on a nationally representative basis, to ask for consumers' views on how long they should have to wait before escalating their complaint. From this research, we recommended that:
- The 8-week rule must be reduced to ideally 2 weeks, but no more than 4 weeks
- Consumers in crisis must be able to involve the ombudsman immediately
- The Department for Business, Energy and Industrial Strategy (BEIS) should include reform of the 8-week rule in its announced Consumer White Paper
Read the full report: Justice delayed: the case for shortening the ombudsman 8-week rule.
In October 2021, the Government broadly supported our proposal to reform the 8-week rule as part of BEIS' consultation on reforming competition and consumer policy. We're still awaiting for the outcome of the consultation to see what action the Government intends to take. Read more in our news story.
Co-authored with the Russell Group of universities, this report called on the Government to scrap the current student loan statement. The report analysed the results of a survey of 5,796 people — made up of students, graduates and parents — who considered MSE and the Russell Group's proposed re-design of the student loan statement. Overall, the survey found that 90% of 2,680 respondents said that the proposed re-design helped them understand the system.
The report also set out a number of recommendations for the Government to take forward, including:
- The Government and the Student Loans Company (SLC) should use the proposed Graduate Contribution Statement as a basis for redesigning the current statement for Plan 1 and 2 graduates as soon as possible.
- The Government should encourage the Office for National Statistics (ONS) to devise a more accurate model to estimate future graduate wage growth.
- The statements of UK graduates working overseas need to be considered further.
- The SLC should provide more information to students and graduates online.
Read the full report: Moving towards a Graduate Contribution Statement.
Our report, Sharper teeth: the consumer need for ombudsman reform was written for the All-Party Parliamentary Group on Consumer Protection. We made four key recommendations for reform of the ombudsman sector, urging the government to make ombudsmen the gold standard in dispute resolution:
Read the full report: Sharper teeth: the consumer need for ombudsman reform.
- All ombudsmen need a statutory basis as a foundation
- Oversight of ombudsmen must be boosted
- The 8-week rule should be shortened and needs vital exceptions
- (Aspiration) Comprehensive ombudsman membership in consumer sectors
The disregarded discount: MSE report into the 'severely mentally impaired' (SMI) council tax discount, September 2017
MSE has been raising awareness of the SMI council tax discount since 2016. In 2017, MSE published a report bringing together its research into the issue with a number of recommendations to improve awareness and uptake of the discount. These included:
- Central and devolved Governments to conduct an urgent review of local authority procedures regarding the council tax SMI discount.
- A standardised application procedure to be introduced across all councils resulting in a clear and simple process for people to claim the SMI discount and rebates.
- Frontline council staff to be adequately trained with a full working knowledge of the discount and how to claim it.
- All councils to allow backdated claims and rebates, alongside implementing a clear policy.
For the full set of recommendations, read the report: The disregarded discount.
Since the report's publication, the Welsh Government and all 22 Welsh local authorities have made every change called for in the report. For more information, see our news story.
What is a consultation and why does MSE respond?
Consultations are used by policy makers to collect opinions on a new area of policy before it’s brought into force. MSE responds to consultations, usually those published by the Government or regulators (like Ofgem or the FCA), to give our views on how a particular policy may affect consumers.
To make sure we’re representing consumers’ interests fairly and accurately, we’ll sometimes ask you to respond to a survey or ask for your experiences of a particular area. We’ll use this insight to point out where policy makers should re-think their plans, or where we think a policy may be particularly helpful.
Our response to the wide-ranging LLE consultation gave some initial comments on specific elements of the proposals. It also highlighted areas that were not in this consultation, but that we felt should be considered by the Department at this stage of the LLE’s development.
We recommended that:
- Government communications should be clearer about the full impact of the LLE proposals.
- The proposed account portal needs to contain information about loan repayments.
- Any means-tested element of student loans should be determined by an independent evaluation process
- A re-evaluation of whose income is included in means testing to take account of current family landscapes where parents split up and start new relationships.
- The Government should retain its policy position of introducing a Sharia compliant student finance system.
We also asked for additional information on:
- The loan repayment terms.
- What, if any, impact on Welsh learners is expected.
- How the Government intends to communicate these changes to learners.
- The method for determining maintenance loan allowance.
In early 2022, MSE submitted a response to the Financial Conduct Authority's (FCA) consultation about its proposed new consumer duty. We broadly welcomed the proposals, and concluded that the change was positive in theory, but had a lot to deliver in practice. We outlined that negative consequences may still arise as a result of the change, and these must be mitigated against. We also thought that effective FCA supervision and enforcement were clearly key to the success of the new Consumer Duty, but we wanted to hear more detail on these points.
We are waiting to hear the outcome of this consultation.
At the end of 2021, Ofgem consulted on its plans to allow it to make changes to the price cap outside of the normal 6-monthly adjustment period, in exceptional circumstances. In our response we expressed concerns that its proposal would not adequately address underlying issues in the market, and would have an unfair impact on consumers. We recommended instead that Ofgem should reduce the current six-monthly assessment period to a shorter period.
On 4 February 2022, Ofgem announced it would give itself powers to change the price cap in 'exceptional circumstances', as a result of the consultation. It also published a further consultation on plans to reduce the current six-monthly assessment to a quarterly assessment. It plans to implement any proposed changes from October 2022. For more information, read our news story on Ofgem's decision.
Financial Conduct Authority: Mortgage consumers, proposed changes to responsible lending rules and guidance, July 2019
Our response to the FCA's proposed plans to help mortgage prisoners was informed by a self-selecting survey of mortgage prisoners, who told MSE about their experiences. Overall, we concluded that the FCA's proposals were welcome, but hugely insufficient as they would only help some. In our response, we set out that a comprehensive solution is urgently needed, and that these proposals would only be a small part of the solution. We said who we thought would not be helped by the proposals, and that HM Treasury has a responsibility to act to help those left behind.
Our response to this call for evidence focused on improvements that could be made to the Plan 2 student loans repayment system (the most current at the time), and was based on our five principle areas of focus:
- Student loans are misnamed and misframed as a debt.
- Students do not have enough money to live off while at university.
- The government must be honest about the parental contribution.
- Student loan statements are misleading and damaging.
- There should be a guarantee of no negative retrospective changes.
Read our full response.
The Government-commissioned Augar report, which used the input from this call for evidence, contained some proposals which were specifically based on our recommendations, and/or attributed to MSE or Martin Lewis. These included renaming the loan as a 'student contribution system' and making the parental contribution explicit. Read more in our news story.
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