BSA response to the FCA/PRA's to the FCA/PRA's consultation on changes to mortgage reporting requirements. 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.