The BSA welcomes the overarching aims and desired outcomes that the measures proposed in CP21/1 set out to achieve.

The BSA is, however, concerned at the proposed charging bands, the construction of which appears to be underpinned  by  a  desire  to preserve the viability of CMC business models. While we acknowledge the stated rationale for this, we consider that basing fee arrangements on a need to ensure there is an incentive for CMC’s to act on behalf of individuals with lower claims has the potential to increase the risk of poor outcomes for consumers.

Read the full response here.