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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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The BSA welcomes the overarching aims and desired outcomes that the measures proposed in CP21/1 set out to achieve.
The BSA's response to the FCA consultation
BSA welcomed this wide-ranging DP and suggests several improvements to the Bank's approach.
We question the benefits of quarterly reporting.
BSA supports Treasury proposals in FRF Review Phase II
The BSA has concerns about the potential side-effects from these proposals and impacts on the housing market.
BSA broadly supports PRA's IRB floors for UK mortgage risk weights but suggests improvements to CP 14/20
Summary BSA and UK Finance response to RICS Cladding consultation: Valuation of properties in multi-storey, multi occupancy residential buildings with cladding
The BSA welcomes to the opportunity to response to the FOS's annual consultation on its plans and budget. While we remain supportive of its stated strategic priorities, we also remain concerned at the continued path to a fundamental change in how the service is funded.
One concern is the proposed transaction fee under the senior managers regime. We believe the FCA should defer further discussion of this proposal until it provides more information and improves the applications process.
The BSA welcomes the opportunity to respond to this consultation on proposed further support for mortgage customers impacted by the coronavirus.
We welcome the PRA's move. But we also argue for a reduction in frequency for the production and review of the recovery plan for those firms eligible for simplified obligations, and for clarity on what "the degree of detail and analysis in a recovery plan should reflect the complexity and size of the firms" means.