Industry responses

As well as proactively campaigning, the BSA frequently comments on consultative papers issued by the Financial Conduct Authority and Prudential Regulation Authority, and by Government departments such as the Treasury or the Department for Business, Innovation and Skills. 

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Our response to HMRC's BBSI improvement proposals

It is clear from the original BBSI proposals, the revised versions, and from follow-up meetings with officials that the MTD plans are vague and aspirational with little consideration of the practical aspects of their implementation.  Some changes are scheduled for the 2018/ 19 return which gives financial institutions (and HMRC) no time to prepare. 

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FCA Mission: Our Future Approach to Consumers

The BSA's response to the FCA's consultation.

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Our response to FCA's consultation on regulatory fees and levies, CP 17/ 38

We argue for the "polluter pays" principle to be applied to the methodology for collecting the Money Advice Service debt advice levy.

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HMT review of the cash ratio deposits scheme

We suggest other beneficiaries of the Bank of England's unremunerated policy work are called upon to fund it.  

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BSA response to DCLG call for evidence on improving the home buying and selling process

The BSA's response to the DCLG's Call for Evidence on improving the home buying and selling process.

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Client money and unbreakable deposits

To be of interest and benefit to the maximum number of building societies (and probably banks), we believe firms should be allowed to deposit client money in unbreakable deposits of up to 95 days.  

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Pillar 2A capital requirements and disclosure

The BSA's response to PRA CP 12/17

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Pillar 2 Liquidity - second consultation

The BSA's response to PRA CP 13/17

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IPPR Commission on Economic Justice

A BSA submission to the Commission's work on supporting mutuals.

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Recovery planning

These requirements appear to go above and beyond the Bank Recovery and Resolution directive.  We are particularly concerned by the "playbook" and "fire drills".

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