Our response to "Regulatory fees and levies: rates proposals 2011/12", FSA CP 11/2 (chapter 10 only)

We argue the proposed user costs for the mutuals register are too high and the proposed service too basic.


The Building Societies Association represents mutual lenders and deposit takers in the UK including all 48 UK building societies. Mutual lenders and deposit takers have total assets of over £365 billion and, together with their subsidiaries, hold residential mortgages of almost £235 billion, 19% of the total outstanding in the UK. They hold more than £245 billion of retail deposits, accounting for 22% of all such deposits in the UK. Mutual deposit takers account for about 36% of cash ISA balances. They employ approximately 50,000 full and part-time staff and operate through approximately 2,000 branches.

Q5: Do you have any comments on the proposed charges for access to public records through the MPR?

The proposal

Chapter 10 sets out the FSA’s plans to change the process, and cost structure, of providing records of mutuals to third parties.

The FSA does not propose to scan archive material, only major new documents as they arrive. Existing documents can be requested and once they are, they will also be provided online. The proposed fees are:

  • £20 per document which requires scanning for the first time.
  • £12 per document available for immediate download.

Currently, charges are based on number of pages with a fixed cost of £27 plus £5 postage. The turnaround time in this new service for hard copies is a maximum of 20 working days. Under the existing system, 90% of requests are dealt with within 15 working days.

Regulatory fees and levies: rates proposals 2011/12, FSA CP 11/2 (chapter 10 only).

Our response

We welcome the move to a straightforward, standard charging system but believe the FSA has missed an opportunity to overhaul the register. A service for mutuals along the lines of the one provided for the corporate sector would, in our opinion, be more appropriate, and timely. There is no reason why mutuals should not too enjoy a modern system with layers of functionality.

Companies House has been providing an online service for well over 10 years. Companies House Direct is a subscription service which currently costs £5 a month and £1 - £2 per document. When this service was first launched the fees for copy documents were higher but have been reduced over the years as the service has become more cost effective.

Therefore, we suggest the FSA moves to introduce a service like Companies House with a similar level of charging. The proposed charges of £20 and £12 per document appear disproportionately high and not justified. Again, it seems as if mutuals are being disadvantaged. Chapter 10.9 says only that, “we sought to ensure that costs of the service are covered and also the expected income is broadly in line with that provided by the existing services”. No further detail, or a cost benefit analysis, is given. This, in our view, is remiss.

Finally, we were surprised to see that the “faster turnaround” for paper documents referred to in chapter 10.7 is 20 working days. That is not fast, neither is it acceptable. If any of our members took 20 working days to perform such a service, it would be accused – quite rightly - of not treating its customer fairly.