A. About the Institute
This submission is made by the Institute of Paralegals. The Institute is a not-for-profit professional
body, incorporated in 2003 and granted Institute status by government in 2005.
We are the lead professional body supporting and representing:
- Unregulated legal practitioners;
- Paralegals employed in the regulated legal sector; and
- Paralegal and unregulated legal staff working in commerce, industry and the public
and third sectors.
The Institute’s interests, membership and remit therefore straddle both the regulated and
unregulated legal sectors. We have both employed and self-employed members, along with
unregulated sector corporate members (i.e. unregulated or “paralegal” law firms).
As well as providing general support and guidance, we set a number of paralegal standards (see
www.theiop.org/national-competency-standards/contract-terms.html) and offer advice on
establishing unregulated legal practices (see www.theiop.org/regulation/regulation-ofparalegals.
We have McKenzie Friend (“MKF”) members and have drawn upon their experiences whilst
responding to this consultation.
For more information about the Institute generally, please visit www.theiop.org.
B. Ownership of The Institute
The Institute is wholly owned by the registered educational charity Instructus (charity number
1144894, but still listed under its old name of Skills CFA).
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Instructus is the UK’s largest registration and certification authority for apprenticeships and work
based education. It is also the leading developer of apprenticeship programmes; accounting for 30%
of all current apprenticeship starts in England, and 3 of the top 4 apprenticeships by volume. As
such, it is the strategic partner of choice for a large number of learners and employers in the UK. For
more information, please visit www.instructus.org.
C. The Professional Paralegal Register
Client protection for users of unregulated legal service providers is a priority for us. As a result, last
year we were one of three paralegal bodies to join together to found the Professional Paralegal
The PPR is a voluntary regulatory scheme open to paralegals/those practicing in the unregulated
legal sector (not all unregulated legal practitioners self-identify as paralegals). Membership of the
PPR is only open to those who are already members of an approved paralegal body (such as the
Part of the PPR’s remit is to protect consumers by helping them to make an informed choice when
retaining an unregulated service provider.
Eligibility for inclusion on the PPR necessitates (i) membership of an approved professional
body/organisation; (ii) ongoing compliance with high standards of probity and competence and (iii)
professional indemnity insurance.
The PPR offers clients of PPR registrants a sympathetic complaints handling mechanism and, if
circumstances warrant, compensation.
The approved professional bodies/organisations must themselves demonstrate that they have a
strong client protection ethos running through their own rules of conduct and complaint handling
For more information on the PPR please visit //ppr.org.uk.
D. About Our Submission
As a result of our said broad remit, we are privy to much feedback from the unregulated sector
about the alleged failings of the regulated sector, and vice-versa. This broad overview of the legal
services market not only informs this response to you, but means that we have no bias towards
either the regulated or unregulated sectors in framing this response.
E. Our Goal
As mentioned below, we believe that all parties, particularly consumers and MKF practitioners
themselves, would benefit if there were in place a recognised MKF training and accreditation
programme providing core skills and standards.
We have MKF members, and have ongoing discussions with MKF practitioners. As a result, we
believe that in partnership with the PPR we have the necessary:
standing with practitioners;
standards setting experience;
training development and delivery capability;
complaints handling system;
professional support and career development/guidance infrastructure; and
to allow the Institute to become the lead professional home for MKFs, and the PPR to provide the
required regulatory function.
We would welcome further discussion on this point if of interest.
F. Consultation Response
We welcome the consultation – and the obvious effort that has been put into it - because the
ambiguity surrounding the status, rights and desirable core skills of MKFs is unhelpful, and the lack
of consumer protection or redress undesirable.
We note that the Working Group has limited its recommendations to those in line with current
legislation and case law. However, we believe that current legislation and case law to be no longer fit
for purpose in a much changed legal environment. We feel that both need to change if we are to
introduce reform which provides litigants in person (“LiPS”) with consumer protection and allows
MKFs to continue to assist them.
To aid cross-referencing, our response follows the paragraph numbering used in the consultation.
1. Paragraph 1.1, Page 3
The entire focus of the consultation is on the role of MKFs when appearing before the court. With
respect to volunteers, friends, family members etc. who assist LiPs with case presentation this is
understandable. Where it is problematic, however, is that it provides an incomplete perspective in
respect of fee-charging MKFs (whom the consultation describes as professional MKFs).
Such fee-charging MKFs are increasingly the norm – and the problem is that fee-charging MKFs are
rarely just MKFs. Typically, they will provide a wide range of advice and assistance to LiPs, working
with them through the entire process from pre-litigation advice and negotiations through to postlitigation
Without taking into account these other bundled services provided to LiPS (and which LiPS need just
as much, if not more, than in-court support) there is a real danger of misunderstanding the role,
motivations and charging structures of the fee-charging MKFs, and the true nature of their
professional relationship with, and importance to, LiPS.
Equally, any consumer protection structures put in place risk not being sufficient to cover the out-ofcourt
services being offered in addition to the in-court services.
On a related matter, we note that the consultation distinguishes between lawyers and MKFs. It is a
distinction that many fee-charging MKFs, and many consumers, would query.
Since the deregulation of the provision of legal services under the Legal Services Act 2007, the
regulated sector has increasingly been mirrored by the fast-growing unregulated sector. Many legal
practitioners in the unregulated sector consider themselves to be lawyers, albeit unregulated ones.
They view themselves as such because they are legal practitioners who practice law and provide
advice and assistance (completely lawfully) to their clients.
It is not regulation that makes a lawyer a lawyer, but the practice of law.
A notary is no less a lawyer because he/she typically has no right to conduct litigation/enjoy rights of
Obviously, this consultation is not the place to debate appropriate terminology for practitioners in
the unregulated sector, but the simple fact is that this growing band of legal practitioners needs to
be described as something, and (unregulated) ‘lawyer’ appears to many of them to be the most
accurate, honest and appropriate title.
Further, giving a distinctive, largely artificial, title to each group of unregulated practitioners (e.g. will
writers, MKFs, debt recovery specialists etc.) will simply confuse consumers further and make it
harder to introduce the consistent sector-wide standards, expectations, protections and support
structures that consumers in the unregulated sector have every right to expect.
The regulated sector is making substantial effort to ensure that consumers have a consistent
experience and enjoy conformity of expectation regardless of which regulated practitioner they
retain. It would be regrettable if the opportunities to put in place a similar structure in the
unregulated sector for the benefit of consumers were missed.
We have been debating with our membership at length about appropriate generic titles for
unregulated practitioners. As mentioned above, it is a complex matter, the discussion of which is
outside the scope of the consultation. For the purposes of this consultation we recommend that the
title ‘MKF’ (without distinction between volunteer and fee-charging MKFs) remain undisturbed until
such time as a wider debate about due recognition of, and nomenclature for, unregulated legal
professionals takes place and that provision be made to refer to such legal practitioners by their
professional titles, so as to distinguish them from friends, work colleagues and other lay assistants.
2. Paragraph 1.5, Page 4
The rise in the use of MKFs is merely a symptom of the fact that a growing proportion of the
population either cannot afford, or perceive they cannot afford, to take legal action to enforce or
defend their legal rights.
This is a major problem requiring a substantial and significant response. It is of concern that the
expected outcomes of the consultation appear to be no more significant than potential changes to
practice rules, and possibly not even that.
We believe that the access to justice issue is genuinely a crisis for the legal system and so requires
major reform. The judiciary should feel empowered to recommend significant reform if that is what
it believes is required to properly address the matter.
The consultation is welcome as a recognition of the important role already played by MKFs, but to
produce the best results for LiPs we would advocate widening its scope to address the reasons that
MKFs exist at all, and having as the absolute priority providing more help to LiPs even if this means
challenging elements of the status quo.
3. Paragraph 2.2, Page 3
The growth in the number of LiPs and MKFs reflects a growing problem, not merely an evolution in
consumer purchasing habits. All things being equal, most LiPs would prefer to retain a
solicitor/barrister but simply cannot afford to do so. Since:
(i) we can see no likelihood of a dramatic decrease in the fees charged by litigation
solicitors/the Bar; and
(ii) the consultation is not suggesting significant changes to court rules which would
reduce costs to litigants,
then we can only presume the problem of unaffordability leading to reduced access to justice will
get worse not better.
Judging from this paragraph of the consultation, the Working Group appears to share that concern.
In the face of such a major challenge faced by LiPs, we are concerned that the recommendations
effectively neuter one of the few successful supports available to them. We say this because taken at
face value, the recommendations appear:
(a) Likely to make the job of fee-charging MKF much less viable, thereby reducing the already
insufficient number of MKFs available to LiPs
(b) To support the replacement of fee-charging MKFs (who have the time, motivation,
commitment and experience to aspire to professional standards) with ad hoc volunteers. We
do not see how replacing professionals with volunteers’ aids consumer protection
(c) To downgrade the professional standing of MKFs by replacing the ‘neutral’ title of MKF with
a title which emphasises the view (with which we wholly disagree) that fee-charging MKFs
are not even legal practitioners
(d) To reduce the scope of the MKF role in court whilst ignoring the MKF out-of court role
(e) To offer nothing in the way of enhanced recognition or support
(f) To increase the procedural and administrative complexity of the MKF role whilst at the same
time saying it should be a volunteer only role
We struggle to identify any recommendation that genuinely enhances LiP protection, choice or
access to justice or which encourages or supports the MKF role.
4. Paragraph 2.3, Page 5
At the end of this paragraph it is noted that the court has the inherent jurisdiction to grant MKFs the
right to conduct litigation as well as having rights of audience. The right to conduct litigation is
granted rarely, as the consultation notes. However, feedback from Institute of Paralegal members
shows that unregulated practitioners typically assist LiPS with their case outside of the courtroom
The legal distinction between an MKF having conduct of the litigation and providing general advice
and support to the LiP is one rarely understood by LiPS. MKFs will prepare letters and documents for
LiPS and liaise with other parties if those other parties will accept their involvement. All too often,
the prohibition is perceived as existing for the benefit of regulated lawyers and not as a consumer
protection mechanism for litigants. Seeing the problems that the restriction causes to all but the
wealthiest we can understand, if not agree, with that view. This is a reserved activity which would
very much benefit from clarification and updating.
5. Paragraph 3.4, Page 11
Towards the end of the paragraph the consultation states “There is no evidence that, what would in
effect be, a wholesale removal of restrictions on rights of audience in the courts is beneficial or
The above quotation presents a false binary choice: maintain the current restrictions or remove
restrictions entirely. Neither is attractive. The obvious third way would be loosening the restrictions
so that a greater range of licensed legal practitioners could help litigants, thus giving litigants access
to less expensive alternatives, the hope of badly-needed innovation in litigation services and,
crucially, freedom of choice.
We would say that continuing to restrict people’s freedom of choice in such an important forum is
neither beneficial nor desirable and should not continue unless there is strong evidence to justify
doing so. It is for those demanding continued limitation on litigants’ rights to justify that limitation.
We suspect that if the current restrictions on the right to conduct litigation and rights of audience
were newly proposed today, neither would receive significant support because there are clearly less
damaging, less anti-competitive, less paternalistic ways of achieving the required consumer
protection. The current rules should not be treated as sacrosanct just because they are a relic of
6. Paragraph 3.6, Page 11
We agree with the Legal Services Consumer Panel that “…the increased use of MKFs, and particularly
fee-paid MKFs, should be ‘recognised as a legitimate feature of the evolving legal services market’,
subject to the implementation of measures intended to improve quality standards and training.”
Improved quality standards and training are key. We are working with the Professional Paralegal
Register and others to map appropriate MKF quality standards and training. We would welcome a
dialogue on both.
7. Paragraph 3.7, Page 11
The consultation paper outlines a number of difficulties arising when using MKFs. That list is not
exhaustive. However, all of the issues raised can be addressed with relative ease - but only if MKFs
have formal recognition before the court.
One of the concerns raised is perhaps the one cited most often in any debate regarding the use of
unregulated legal practitioners: “…a lack of consumer protection by reason of a lack of effective
This is obviously a legitimate concern. However, any potential harm from proceeding needs to be
weighed against the actual harm already being suffered by consumers, not to mention the
prohibition on consumer choice and anti-competitive outcomes which also need to be justified.
In this instance the risk of some harm potentially happening to some litigants using MKFs is vastly
outweighed by the actual harm already happening to many litigants by their being priced out of the
system. Further the legitimacy of the legal system itself is damaged as it is seen as beyond the reach
of many consumers. In essence, it is a poor consumer protection argument that says consumers are
best protected by ensuring that they cannot afford to buy anything, and thus at no risk of receiving
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8. Paragraph 4.4, Page 13
Titles are important. Feedback from members and other unregulated sector practitioners is that
most consumers view legal practitioners as lawyers, and that confusion very quickly sets in when
other titles (even well-established ones) are used. An important part of consumer protection is
consumer education. Good consumer education is best built upon clear, consistent, straightforward
messages. Creating new practice titles for each unregulated sector practice will cause further
The consultation recommends “…the term MKF should…be replaced by a term that is easily
understandable and properly reflects the role in question”. With respect, we disagree.
As mentioned previously, in our experience fee-charging MKFs typically offer the MKF role as part of
holistic ongoing case support for the LiP. Their MKF role is one role amongst many, and often a very
minor role (because most cases settle outside of the courtroom). To define their many roles by
reference to just one of them will create confusion. Also, as a matter of principle, this approach is
not taken with regulated lawyers, so why apply it unregulated practitioners? A high street solicitor
may undertake 20 different roles in a day, but his/her job title of ‘solicitor’ does not change.
Again, to reduce consumer confusion, whenever possible, reasonable and appropriate, the
unregulated sector should mirror regulated sector practices.
9. Paragraph 4.5, Page 14
We agree with the Working Group that retitling MKFs as ‘lay advisors’ is not helpful. We dislike the
term for different reasons however.
An increasing number of fee-charging MKFs are professional legal advisers and not lay advisors. They
are legal practitioners who are currently unregulated. Again we have to question the underlying
assumption that only a regulated lawyer can be deemed a lawyer or legal professional. Times
change, and the existence of a huge and growing unregulated legal sector containing many
professional and diligent legal practitioners needs to be recognised in a manner which does not:
(a) create get more confusion in the public; and
(b) label them in a manner which denies their professional legal practitioner status.
10. Question 1, Page 14:
Do you agree that the term ‘McKenzie Friend’ should be replaced by a
term that is more readily understandable and properly reflects the role in question?
For the reasons given above:
No, we do not think that the term ‘MKF’ should be dropped until proper debate is had and
consideration given to the wider role typically played by both volunteer and fee-charging
No, in respect of fee-charging MKFs, a title that reflects the in court role they play is likely to
be inaccurate and misleading given their out-of-court support services.
It is our view that fee-charging MKFs should adopt a legal practitioner title and that it be
acknowledged that the in-court role is just one of many roles played by such MKFs in their capacity
as legal advisers.
Much of the confusion we have today about who can do what stems from the historical practice of
job titles being linked to roles. However, in the modern world where roles are fluid, it is just an
added layer of confusion to have to explain changes to busy members of the public, e.g. that
Licensed Conveyancers can now sometimes do probate work and Chartered Legal Executives have
rights of audience. It would be unfortunate if steps were taken to actively perpetuate and grow that
11. Question 2, Page 15:
Do you agree that the term ‘court supporter’ should replace McKenzie
Friend? If not, what other term would you suggest?
In respect of non-fee-charging MKFs, we do not like the term “court supporter” for the reasons given
Further, and again in respect of fee-charging MKFs only, we are also concerned about its inherently
subordinate, low-ranking nature which denies the professional legal practitioner status of feecharging
MKFs. ‘MKF’ has two advantages over terms such as ‘court supporter’ or ‘lay adviser’ for
fee-charging MKFs. Firstly it is a term with which the public has become familiar and, secondly, it is
professionally neutral and non-judgemental, unlike the proposed alternative.
Titles are extremely important and it would be unfortunate if the current proposals were
misconstrued as an attempt by regulated lawyers to hobble their unregulated competition.
As to which title or term we would suggest, this would be dependent upon the extent of recognition
and regulation imposed upon future fee-charging MKFs in respect of their involvement in the
litigation process generally. We are surprised that thought is being given now to a role-based name
before the scope of that role has been properly mapped. We would propose that we work with
other stakeholders to map the true extent of the holistic MKF role so further advance the debate.
12. Question 3, Page 16:
Do you agree that the present Practice Guidance should be replaced with
rules of court?
Not necessarily. We believe the present Practice Guidance has worked well. To the extent the
changes are needed, we believe them to be much further reaching than the proposed changes to
the rules of court. We believe that MKFs should be regulated and meet minimum quality and
training standards and that, when they do, they should have rights of audience and the right to
conduct litigation. This is the model being adopted by the Professional Paralegal Register and so the
mechanism already exists to achieve this. We acknowledge the potential problems that extending
the rights of MKFs would bring, but we believe those future potential problems to be dwarfed by the
current crisis of lack of access to justice.
13. Question 4, Page 16:
Should different approaches to the grant of a right of audience apply in
family proceedings and civil proceedings?
No. The issue of the unaffordability of regulated lawyers is widespread. Although the advent of LiPS
and MKFs is perhaps felt most keenly in the family division, their presence is increasing across most
areas of civil proceedings not dominated by corporate litigants. This is a system-wide issue and
should be addressed in a uniform manner across the civil justice system.
14. Paragraph 4.12, Page 17 con
We do not agree with the prior notification proposal because:
Aside from the unaffordable cost of regulated lawyers, the main barrier to stopping
consumers using the civil justice system is its complexity. This is a step towards more
complexity for little or no real benefit.
It is contradictory for the consultation to propose the de facto squeezing out of fee-charging
MKFs but then to start adding multi-element, tri-partite, legally binding, sophisticated
contractual procedural obligations onto the ad hoc volunteer MKFs least able to understand,
need or handle the same.
It will require a level of pre-planning and certainty that many LiPS may not be able to comply
with. Is the intention to stop the MKF supporting the LiP if the notification is not filed? If yes,
then it defeats the whole purpose of MKFs. If not, then it is a bureaucratic step for the
benefit of the court to the detriment of LiPS, and again defeats the whole purpose of MKFs.
The information about the role, rights and responsibilities of the MKF is useful but mistimed
in respect of fee-charging MKFs who are also assisting out-of-court (i.e. most of them). That
information should be given to the LiP at the point at which the LiP is considering using the
MKFs services. This will usually be quite some time before the actual court hearing. What is
needed is an initial retainer letter. We appreciate this is outside the scope of the court’s
jurisdiction, but that just seeks to highlight once again that it is inappropriate to just focus
solely on the in-court portion of the MKF role, and that to do so will just create problems for
LiPS elsewhere in the litigation process.
15. Paragraph 4.14, Page 17
This paragraph demonstrates the complexity of the matter. What is labelled as a simple notification
of intent quickly blossoms into a retainer letter, a binding contract, undertakings to the court, the
submission of sworn evidence/information and more. This proposal is trying to do too much and is
not workable. Again, either MKFs are volunteers helping out LiPs, in which case the focus should be
on the LiP and not their “mouthpiece”, or the MKFs are important legal representatives requiring
scrutiny in their own right - in which case they ought to have the recognition and enhanced rights
that many seek. This proposal does not provide a solution in either circumstance.
16. Question 5, Page 17:
Do you agree that a standard form notice, signed and verified by both
the LiP and McKenzie Friend, should be used to ensure that sufficient information is given to
the court regarding a McKenzie Friend?
No, for the reasons given above.
A simple form supplied either just before or at the beginning of the hearing with some basic
information about the MKF would be sensible, but the proposal as is turns it from a standard form
notice into a highly complex, legally binding, multi-document submission. This is the exact opposite
of making things simpler for LiPs. Further, the complexity and personal responsibilities imposed
upon the (presumably volunteer) MKFs is both inappropriate and likely to be off-putting and of
questionable necessity to many. There is a significant contradiction between the role of MKFs as
volunteer helpers and the quasi-contractual obligations imposed by the suggested ‘notice’ which
would be more suitable for fee-charging MKFs.
17. Question 6, Page 18:
Do you agree that such a notice should contain a Code of Conduct for
McKenzie Friends, which the McKenzie Friend should verify that they understand
and agree to abide by?
Again, the proposed contents make this much more than a simple notice. It would not hurt to have
such a Code of Conduct, but we see significant problems in making such a Code of Conduct fit the
reality of the totality of support provided by fee-charging MKFs. Further, unless fee-charging MKF’s
are prohibited (a damaging, anti-competitive, unhelpful and retrograde step) then we do not see
how a Code of Conduct can easily encompass both types of MKF. Should a Code of Conduct be
introduced, then it would have to be strictly limited to in-court activities. However, the overlap
between a presumably voluntary Code and the enforceable expectations of the Court need to be
18. Question 7, Page 19:
Irrespective of whether the Practice Guidance (2010) is to be revised or
replaced by rules of court, do you agree that a Plain Language Guide for LiPs and
McKenzie Friends be produced?
Yes, this would be helpful, provided it was written with the input of MKFs and other stakeholders.
19. Question 8:
If a Plain Language Guide is produced, do you agree that a non-judicial
body with expertise in drafting such Guides should produce it?
Yes, this would be helpful, provided it was written with the input of MKFs and other stakeholders.
An effective guide needs to be able to see things through the eyes of LiPs and MKFs.
20. Paragraph 4.24, Page 20
We acknowledge the undoubted difficulties that would arise in bringing free-charging MKFs within
the existing cost recovery structure. We are also very mindful of the potential for MKF cost recovery
to undermine the current restrictions on the right conduct litigation and rights of audience.
Nevertheless, on the grounds of fairness and equality we advocate allowing at least partial recovery
by LiPs of their MKF costs.
We are facing a crisis with regards to access to justice. That crisis has been brought about primarily
by the unaffordable fees charged by regulated lawyers and the procedural complexity of the system
(the two being linked of course). The only even half-workable, ad hoc solution has been MKFs to
support LiPs. The Working Group frequently raises concerns about the quality of MKFs. Given this, it
is disappointing that the consultation suggests replacing fee-charging MKFs with ad hoc, occasional
volunteers and increasing the complexity of the procedure involving MKFs.
Relying on ad hoc volunteers is not a credible route to improving standards amongst MKFs, nor will it
encourage more MKFs.
What is more credible is to encourage MKFs who can commit the time necessary to gain expertise
not only in court procedure, but in client care, complaint handling and other elements that feed into
an acceptable level of client care. For example, volunteer MKFs rarely produce retainer letters, have
professional indemnity insurance or a formal complaints procedure.
For MKFs to have the time, expertise and resources to do this they need to be fee-charging MKFs.
That is why we are disappointed that the Working Group is opposed to allowing LiPs to recover their
wholly legitimate legal costs when successful – costs which would be recoverable if submitted by a
solicitor or barrister. Job titles should not become a major barrier to access to justice.
Given that most LiPs are LiPs through necessity not choice, it is reasonable to assume that most will
struggle to pay even MKF charge-out rates. The notion that they should not be allowed to recover
their costs in a successful case simply because of their choice of advocate rather than the legitimacy
of their claim is both unfortunate and punitive. Regrettably, it gives the no doubt false impression
that preserving the regulated lawyer monopoly is considered more important than the needs of
litigants or easy access to justice. If the court system is genuinely there to serve members of the
public, then the most economically vulnerable of them (LiPs) should be given priority in reclaiming
their costs, not penalised for choosing an unregulated advocate.
Again, we find ourselves in the curious position where penalising all consumers (LiPs) through an
inability to recover their legitimate costs is presented as a consumer protection.
21. Question 9, Page 21:
Do you agree that codified rules should contain a prohibition on feerecovery,
either by way of disbursement or other form of remuneration?
No. Whilst a number of pro bono bodies, Citizens Advice, et cetera do a wonderful job assisting LiPs,
they are a drop in the ocean when compared to unmet need. To address the crisis of lack of access
to justice we need more affordable legal representatives. Ad hoc occasional volunteer MKFs do not
meet this requirement. Licenced fee-charging MKFs meeting agreed standards of training,
competency and client care do.
For MKFs to exist in sufficient number, and for them to be sufficiently experienced and trained and
licensed to ensure sufficient quality and consumer protection, they need to be fee-charging.
22. Question 10, Page 22:
Are there any other points arising from this consultation on that you
would like to put forward for consideration?
We believe the focus on this consultation is too narrow. We think it would have benefited from a
more holistic approach in which court hearings were seen as part of an ongoing process which
begins before court action is initiated and continues after it has concluded.
We also believe that fee-charging MKFs should be encouraged, not discriminated against.
LiPs need assistance with the whole process, not just in-court hearings. Many people never get to be
LiPs because they cannot afford the legal advice and assistance needed to even initiate legal action.
That situation does not look like it is going to change any time soon, for a whole series of complex
reasons. Accordingly, we agree with the Legal Services Consumer Panel that MKFs are here to stay.
The question is will the court system assist LiPs by accommodating fee-charging MKFs as much as
reasonably possible, or will it put up barriers to them. It is of concern that it not clear from this
consultation which way matters will go, although we are hopeful of positive reform that gives
priority to helping LiPs and not preserving the broken status quo.