Consultation Response
One of the sneakier bits slipped into George Osborne's budget a few weeks back was a proposal to retrospectively alter the threshold at which students start to pay back Student Loans. This is currently £21,000, but should go up in line with inflation each year. The government is now proposing to remove this indexation. Yes, even for existing loans. The consultation document is at at https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/447565/BIS-15-445-student-loan-repayment-threshold-consultation.pdf
My response to the consultation :
1 What is your name?
Peter Sullivan
2 What is your email address?
[redacted]
3 What is your organisation?
Not applicable - personal response
4 Keeping the threshold of £21,000 the same for all post-2012 borrowers until April 2021? (Option 1)
Whilst there may be a case for applying this to new loans taken out going forwards, there can be no case for applying this to loans which students have already committed to. The government would not allow private sector lenders to change the terms of a loan if the lender decided they no longer wished to fulfil them; it should apply the same fiscal discipline and principles of equity to its own loan book.
You note that "the proportion of borrowers liable to repay when the £21,000 threshold takes effect in April 2016 will be lower than was expected when the policy was initially introduced." This is because of the slow pace of growth in the economy, not because of any windfall benefit to the students impacted.
I note that I personally have a number of savings with NS&I, which I invested in, at least in part, because of the security and certainty of the loan terms and return. Will the government be looking to apply a similar principle of retrospectively changing the terms of these loans to its own benefit?
5 For borrowers starting in September 2016 (and subsequent intakes), from April 2020 keeping the threshold at the same level as existing borrowers for a further five years? (Option 2)
I personally would prefer no change, but Option 2 does not suffer from the equity objections to option 1.
6 Allowing the threshold to rise by earnings? (No change)
This would be my preferred option. If this is unaffordable, then option2 would be better.
7 Current students/borrowers?
Represents a unilateral change by the lender of the terms of the loan which the students agreed to when they signed up.
8 Prospective students/new borrowers?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place.
9 Employers of borrowers with loans?
Minimal - their job is to make the deductions as advised by SLC & HMRC.
10 The Student Loans Company (SLC) and HM Revenue and Customs (HMRC)?
Some administrative overhead, but this should be minor as long as they have sufficient advance knowledge to adjust.
11 Learning providers?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place. Impact on providers' equality and diversity strategies.
12 The Tax payer?
Perception that loans to/from the government are "political" and can be changed at whim. That the government is an untrustworthy counter-party for loan transactions.
13 Can you identify any equality issues introduced by these possible changes?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place.
14 Do you think the Government could mitigate the impact of the proposed changes for borrowers?
Yes
15 If yes, what do you consider those actions might be? (Please indicate all that you consider to be relevant)
Introduce Option 2 - only apply freezing of threshold to new borrowers, who can then take this into account in deciding whether or not to go to university.
Note that students part-way through a course are not "new borrowers" as they have already committed to their course, and hence future borrowing, unless they drop out.
16 Do you have any other comments that might aid the consultation process as a whole?
Many young graduates I know are currently in low-paid jobs that do not require graduates. This is not due to any lack of effort on their part, but to the general
economic situation. The £21,000 threshold - and its indexation - plays a key role in making sure that graduates only have to pay for their university education
once they start to benefit from it.
My response to the consultation :
1 What is your name?
Peter Sullivan
2 What is your email address?
[redacted]
3 What is your organisation?
Not applicable - personal response
4 Keeping the threshold of £21,000 the same for all post-2012 borrowers until April 2021? (Option 1)
Whilst there may be a case for applying this to new loans taken out going forwards, there can be no case for applying this to loans which students have already committed to. The government would not allow private sector lenders to change the terms of a loan if the lender decided they no longer wished to fulfil them; it should apply the same fiscal discipline and principles of equity to its own loan book.
You note that "the proportion of borrowers liable to repay when the £21,000 threshold takes effect in April 2016 will be lower than was expected when the policy was initially introduced." This is because of the slow pace of growth in the economy, not because of any windfall benefit to the students impacted.
I note that I personally have a number of savings with NS&I, which I invested in, at least in part, because of the security and certainty of the loan terms and return. Will the government be looking to apply a similar principle of retrospectively changing the terms of these loans to its own benefit?
5 For borrowers starting in September 2016 (and subsequent intakes), from April 2020 keeping the threshold at the same level as existing borrowers for a further five years? (Option 2)
I personally would prefer no change, but Option 2 does not suffer from the equity objections to option 1.
6 Allowing the threshold to rise by earnings? (No change)
This would be my preferred option. If this is unaffordable, then option2 would be better.
7 Current students/borrowers?
Represents a unilateral change by the lender of the terms of the loan which the students agreed to when they signed up.
8 Prospective students/new borrowers?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place.
9 Employers of borrowers with loans?
Minimal - their job is to make the deductions as advised by SLC & HMRC.
10 The Student Loans Company (SLC) and HM Revenue and Customs (HMRC)?
Some administrative overhead, but this should be minor as long as they have sufficient advance knowledge to adjust.
11 Learning providers?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place. Impact on providers' equality and diversity strategies.
12 The Tax payer?
Perception that loans to/from the government are "political" and can be changed at whim. That the government is an untrustworthy counter-party for loan transactions.
13 Can you identify any equality issues introduced by these possible changes?
Might discourage prospective students, especially those from poorer backgrounds, from applying to university in the first place.
14 Do you think the Government could mitigate the impact of the proposed changes for borrowers?
Yes
15 If yes, what do you consider those actions might be? (Please indicate all that you consider to be relevant)
Introduce Option 2 - only apply freezing of threshold to new borrowers, who can then take this into account in deciding whether or not to go to university.
Note that students part-way through a course are not "new borrowers" as they have already committed to their course, and hence future borrowing, unless they drop out.
16 Do you have any other comments that might aid the consultation process as a whole?
Many young graduates I know are currently in low-paid jobs that do not require graduates. This is not due to any lack of effort on their part, but to the general
economic situation. The £21,000 threshold - and its indexation - plays a key role in making sure that graduates only have to pay for their university education
once they start to benefit from it.