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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Simplified obligations for recovery planning

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.

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Non-systemic UK banks : the PRA's approach to new and growing banks

BSA welcomes corrective prudential,action on new and fast-growing banks

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Amendments to HMRC's civil information powers

Our written evidence to the House of Lords sub-committee on the draft Finance  Bill 2020-2021.

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PRA's implementation of CRD V

BSA broadly supports PRA proposals but challenges PRA to be more ambitious in cutting compliance burdens

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FCA CP19/32 Building operational resilience: Impact tolerances for important business services and feedback to DP18/04

We support proposals set out in the consultation paper to strengthen operational resilience, but we ask for further clarification and guidance on some specific areas.

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PRA CP29/19 Operational resilience: Impact tolerances for important business services

We support proposals set out in the consultation paper to strengthen operational resilience, but we ask for further clarification and guidance on some specific areas.

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Outsourcing and third party risk management

We urge the PRA to review all its deadlines, particularly the one for the review of legacy outsourcing agreements, which we believe should be extended until at least 2023.   This is especially important if the prudential context element is going to draw third party arrangements into the material outsourced classification.  

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CRD V Implementation in the UK

BSA supports continued CRD exemption for credit unions

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