The BSA responded to the FCA/PRA's consultation on changes to mortgage reporting requirements. Given the large increase in product transfers in recent years, we were sympathetic to the FCA and PRA's rationale for expanding the data reported for it to better analyse and predict market trends. However, feedback from members to the consultation shows some firms to be extremely concerned about how they will apply the changes to the proposed changes to PSD001.

The full response can be found here. We made the following recommendations.

• Expand the data fields in PSD007 to better capture internal product transfers and use this for smaller firms up to an annual gross mortgage-lending limit of £100m
• Extend the time period for firms to adopt the new reporting processes from 12 months to 18 months of publication of the final rules
• Ensure the Gabriel test environment is built and fully functional in tandem with publication of the final rules.