Information - Industry responses

BSA responds to CP13/24 - securitisation

The BSA has responded to the PRA consultation CP13/24 on securitisation, including the treatment of mortgage guarantee schemes

BSA Responds to CP2/25 proposals to increase threshold for leverage ratio framework

The BSA responds to the PRA's CP2/25

BSA responds to CP7/24, CP8/24 and CP9/24

The BSA has responded to the PRA's consultation on the capital aspects of the new regime for Small Domestic Deposit-takers (SDDT).

Broadening access to financial advice for mainstream investments

The BSA supports the broad aim of the FCA’s Consumer Investment Strategy for a consumer investment market in which consumers can invest with confidence, understanding the risks they are taking and th...

BSA responds to MREL consultation

The BSA has submitted its response to the Bank of England.

BSA responds to the Bank of England discussion paper on transitioning to a repo-led framework

The BSA has responded to the Bank of England's discussion paper on transitioning to a repo-led framework

BSA response to FCA CP25/11: Mortgage Rule Review

The BSA welcomes the opportunity to comment on the Mortgage Rule Review.

BSA response to HMT Common Bond Reform call for evidence

The BSA and NCUF welcome the opportunity to feed into HM Treasury’s planned reform of common bonds.

BSA response to PRA CP17/24 and FCA CP24/28 on operational resilience: operational incident and outsourcing and third party reporting

BSA Response to Treasury Committee Inquiry into the Lifetime ISA

Financial Ombudsman Service Our 2025/26 Plans and budget consultation

The BSA has responded to the Financial Ombudsman Service Our 2025/26 Plans and Budget consultation.

FOS & FCA Call for input on modernising the redress system

The BSA has responded to the Financial Ombudsman Service and Financial Conduct Authority joint call for input on modernising the redress system.

HMT Financial Services Growth & Competitiveness Strategy

The BSA's submission to HM Treasury's Call for Evidence on its Financial Services Growth & Competitiveness Strategy

Improving the home buying and selling process

Decarbonising Home Heating

PRA and FCA joint consultation on Remuneration Reform

Building Societies Association response to CP16/24

Reforming the Energy Performance of Buildings Regime

Retrofitting our homes for a net zero future

Labour's new deal for leaseholders

The BSA has responded to Labour's proposals for leaseholders.

BSA response to Law Commission consultation; Leasehold home ownership: buying your freehold or extending your lease.

The BSA welcome the Law Commission’s proposals which support governments recent work to simplify and make the leasehold process more fair for leaseholders. The paper looks at simplifying the enfranch...

Shared Ownership

BSA response to LUHC Committee shared ownership inquiry

Review of FCA requirements following the introduction of the Consumer Duty

The BSA is delighted to have the opportunity to contribute to the FCA’s review of requirements following the implementation of the Consumer Duty.

Resolution assessments: amendments to reporting and disclosure dates

The BSA supports the PRA’s proposals in CP12/24 on the Resolvability Assessment Framework

BSA Autumn Budget 2024 Submission

The BSA's submission to the Chancellor, ahead of the Autumn Budget.

FOS Consultation on charging Claims Management Companies & other professional representatives

The BSA strongly supports the principle of charging a fee to CMCs.

Common Reporting Standard Consultation

The BSA Reponds

PRA's Approach to Policy

Recapitalisation - Enhancing the Special Resolution Regime

BSA Response to HMT Consultation

BSA Response to CP1/24 - FSCS MELL 2024/25

Strengthening protections for borrowers in financial difficulty

FPC affordability test consultation

The Appointed Representative regime

BSA response to the HM Treasury call for evidence

BSA response to CP21/34

BSA response to CP21/34 - Improving the Appointed Representative regime

Further proposals to support mortgage borrowers impacted by coronavirus

The BSA welcomes the opportunity to respond to this consultation on proposed further support for mortgage customers impacted by the coronavirus.

Regulation of insolvency practitioners, review of the regulatory landscape.

The BSA has responded to the consultation which examines the currently system of Recognised Professional Bodies (RPBs) regulating insolvency practitioners.

Mortgage customers: proposed changes to responsible lending rules and guidance

The BSA has responded to FCA proposals to help Mortgage Prisoners by enabling lenders to utilise a modified affordability assessment.

BSA response to HM Treasury breathing space scheme: consultation on a policy proposal.

These proposals present significant complexities to mortgage lenders and would mean significant disruption to existing systems and processes which work well for the benefit of customers.

Peer-to-peer and crowdfunding platforms

We agree with the spirit of the consultation which addresses a potential gap in protection for consumers choosing to apply for home finance via a Peer to Peer (P2P) platform.

BSA response to FCA Mortgage Market Study: Interim Report MS16/2

The BSA response to the FCA Consultation

BSA publishes submission to FCA Mortgages Market Study interim report

Public Financial Guidance

Spring Budget 2024: Helping First Time Buyers and Savers

The BSA has written to the Chancellor ahead of his Budget on 6 March.

CP9/23 The Bank of England's approach to enforcement: proposed changes and clarifications

The BSA response to Bank of England CP9/23. The Bank has now published PS1/24 providing feedback to CP9/23 and also contains the Bank's final policy.

Response to CP23/22 FCA Regulated Fees and Levies 2024/25

BSA Response to the 2024/25 FCA Fees and Levies consultation.

BSA Response to House of Lords Regulators Inquiry

BSA Response to House of Lords Inquiry on UK Regulators

Diversity & Inclusion in Financial Services

BSA response to FCA CP23/20 and PRA CP23/18

FSCS Electronic Transfer of Compensation

FRC Revisions to the Ethical Standard

BSA Response to FRC Ethical Standard Revisions

BSA Response to CP15/23 Securitisation

The BSA supports the PRA's approach to securitisation

Solvent Exit Planning for Non-Systemic Firms

Summary of solvent exit planning requirements for building societies

Autumn Statement 2023: Helping First Time Buyers and Savers

The BSA highlights four proposals that would help first time buyers to step onto the property ladder and savers to build their financial resilience.

PRA's Future Approach to Policy Making

The BSA's Response to CP 11/23 "PRA's Statement on the Review of Rules"

GC23-2 FCA Guidance consultation on financial promotions on social media

Our response to FCA GC23-2

FRC UK Corporate Governance Code consultation 2023

Our response to the FRC's consultation on changes to the UK Corporate Governance Code

Reporting on regulatory capital: choices for assurance

We see no benefit for building societies in these PRA-driven proposals.

Non-performing exposures - capital deduction

The BSA supports the proposals in CP6/23 to remove the capital deduction for non-performing exposures.

HMR consultation, "A bank levy banding approach"

Financial Reporting Council - Competition in the audit market

Increasing capacity and competition in the audit marketplace is a very important topic for our members.

FCA Credit Information Market Study Interim Report - MS19/1.2

The BSA responded to the Financial Conduct Authority's Credit Information Market Study Interim Report, which can be found here.

Implementation of the Basel 3.1 Standards

The BSA publishes its response to CP16/22 – the PRA’s implementation of Basel 3.1

FCA regulated fees and levies: rates proposals for 2023/24

The BSA has submitted its final response to CP23/7.

RICS cladding consultation

Summary BSA and UK Finance response to RICS Cladding consultation: Valuation of properties in multi-storey, multi occupancy residential buildings with cladding

Money Advice Service and the coordination and provision of debt advice

The Strong and Simple Framework: Liquidity and Disclosure requirements for Simpler-regime firms

The BSA is a strong supporter of the 'Strong and Simple' project and welcomes the proposals included in CP4/23, while also believing that the proposals could go further.

HM Treasury Call for Evidence: Senior Managers & Certification Regime

The BSA's response to HM Treasury's call for evidence on the Senior Managers & Certification Regime

Our response to the PRA's Buy-to-let underwriting standards consultation

The BSA has responded to the Prudential Regulation Authority's (PRA) Buy-to-let underwriting standards consultation, which looks to introduce tighter underwriting standards for buy-to-let lending, in ...

Bank of England requirements for a loan-level data collection for buy-to-let

The BSA responded to a 2016 Bank of England consultation on proposals for a loan level data collection for buy-to-let. The current threshold level for the buy-to-let data requirements is £20m of new b...

CP7/23 - Regulated fees and levies: Rates proposals 2023/24

BSA response to PRA CP7/23: Regulated fees and levies: Rates proposals 2023/24

FOS Our 2023/24 plans and budget Consultation

The BSA has responded to the Financial Ombudsman Service's consultation Our 2023/24 plans and budget.

Regulated fees and levies: Rate proposals 2023/2024

BSA responds to FCA Consultation CP22/23 Fees and levies proposals for 2023/2024

PRA Approach to supervising credit unions

The BSA responds to the PRA's CP7/22 Credit Unions: Changes to the regulatory regime

Guidance for firms supporting borrowers impacted by the rising cost of living

BSA welcome FCA guidance for firms supporting borrowers impacted by the rising cost of living. We are pleased that the focus remains on forbearance tailored to the individual borrower's needs and circumstances

PRA Approach to Policy

The BSA has responded to DP4/22 The PRA's approach to policy

BSA Evidence to Financial Services Bill Committee

Summary of BSA remarks at Financial Services Bill Committee

Accounting, Reporting and Governance Authority

BSA response to the FRC's consultation on the funding of the new Accounting, Reporting and Governance Authority (ARGA). We argue for a proportionate approach using a 'polluter pays' principle.

Model risk management principles

The BSA broadly supports the proposals and calls for proportionate implementation and cautions against a maximalist approach.

Decarbonisation of housing: decarbonising the private housing sector

BSA response to the Climate Change, Environment, and Infrastructure Committee of the Senedd Cymru.

Creating a funding model for the future: A Discussion Paper

The BSA welcomes the opportunity to respond on behalf of its members to the FOS’s discussion paper on creating a funding model for the future. It is helpful and encouraging that the FOS is seeking vie...

The Strong and Simple Framework : a definition of a Simpler-regime firm

BSA maintains support for PRA's overall Strong and Simple initiative

Supporting liquid asset usability

BSA welcomes the Bank's engagement with enabling better use of HQLA buffers, and we contribute insights from our members

Regulated fees and levies: rates proposals 2022/ 2023

Our main concerns relate, as ever, to cost control and to the lack of an appropriate fees tariff for building societies.

FCA regulated fees and levies: rates proposals for 2022/23

We submit a brief response highlighting again concerns about cost control.

The Future of Insolvency Regulation

The BSA's repsonse to the Government consultation

Amendments to the Building Societies Act 1986

The BSA welcomes the Government's proposals to amend the Building Societies Act 1986, and supports the individual measures proposed, many of which derive from the BSA’s own advocacy. We are pleased to...

CP21/36: A New Consumer Duty

The BSA responds to the FCA's CP on A New Consumer Duty

Future Regulatory Framework Review

BSA responds supportively to Treasury's proposals for reform, and makes suggestions for improvement.

CP21/30: Debt Packagers - proposals for new rules

The BSA strongly supports the FCA's proposals.

Review of the cash ratio deposit scheme: consultation on proposed changes

The costs of funding the Bank of England's policy costs should be widened to include large firms in other FS sectors such as insurers. We support the introduction of a levy but are concerned that the...

Strengthening The Pensions Regulator's Powers: Notifiable Events (Amendments) Regulations 2021

We urge DWP to look again at the proposed reporting requirements for “notifiable events”. There could be unintended consequences for building societies (and other regulated financial services busine...

Budget 2021

The BSA's Submission ahead of the Autumn Budget

Responses to the HM treasury consultation & call for evidence on money laundering & terrorism financing, 2021

Draft Finance Bill 2021-22

The Finance Bill Sub-Committee has consulted on two areas of the draft Finance Bill 2021-22

Diversity & Inclusion in the financial sector - working together to drive change

The BSA and its members strongly support the steps being taken by the Bank of England, PRA and FCA to engage in a more formal dialogue on diversity and inclusion.

Reforming competition and consumer policy

Our response to the BEIS Reforming competition and consumer policy consultation

Reviews of Wholesale Securities Markets and the Prospectus Regime

BSA responds briefly on reviews of wholesale markets and the prospectus regime.

Minimum Requirements for Eligible Liabilities

BSA broadly supports Bank's further proposals on MREL

Reforming the framework for Better Regulation

BSA supports reform of Better Regulation Framework along lines of TIGRR report.

Access to Cash Consultation

The BSA responded to HM Treasury's Access to Cash consultion.

The UK Leverage Ratio Framework

BSA broadly supports (most of) the proposals in the two linked CPs.

FCA Call for Input on Open Finance

The BSA has responded to the FCA's Call for Input on Open Finance, which looks to bring Open Banking data standards to a wider range of financial products and services.

Strong and simple - DP 1/21

Ring-fencing and Proprietary Trading Independent Review

Read the BSA's submission to the call for evidence.

Restoring trust in audit and corporate governance

We believe that building societies other than the largest should not fall within the definition of a public interest entity.

Balance of Competences review

Our response to FCA regulated fees and levies: rates proposals 2021/ 2022

Our main concerns relate to cost control and to the lack of an appropriate fees tariff for building societies.

CP21/1: Restricting CMC charges for financial products and services claims

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

CP21/4: Funeral Plans: Proposed Approach to Regulation

The BSA's response to the FCA consultation

APPG Financial Markets: Consultation on the role of the UK parliament in the future regulatory framework for financial services

BSA response to the APPG

MREL approach Discussion Paper

BSA welcomed this wide-ranging DP and suggests several improvements to the Bank's approach.

Making tax digital for corporation tax

We question the benefits of quarterly reporting.

Financial Services Future Regulatory Framework - Phase II Review

BSA supports Treasury proposals in FRF Review Phase II

BEIS improving home energy performance through lenders consultation

The BSA has concerns about the potential side-effects from these proposals and impacts on the housing market.

UK mortgage risk weights - IRB floors

BSA broadly supports PRA's IRB floors for UK mortgage risk weights but suggests improvements to CP 14/20

FCA regulatory fees and levies: policy proposals for 2021/ 2022

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 a...

FOS consultation "Our 2021/22 plans and budget"

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 th...

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

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

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 wh...

Amendments to HMRC's civil information powers

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

PRA's implementation of CRD V

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

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.

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.

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 importa...

CRD V Implementation in the UK

BSA supports continued CRD exemption for credit unions

Transposition of BRRD 2 in the UK

BSA challenges potential freezing of customer deposits under BRRD 2 moratorium power

Pillar 2A: Reconciling capital requirements and macroprudential buffers

BSA challenged unfair PRA offsetting proposals

Environmental Audit Committee energy efficiency inquiry

BSA response to energy efficiency inquiry

FCA Guidance Consultation on branch and ATM closures

In GC20/2, FCA sets out planned guidance for banks, building societies and credit unions to follow when planning closures of branches or ATMs or converting ATMs from free to customer to fee-charging.

Government consultation on expanding the dormant assets scheme

The BSA response to the Government consultation paper on expanding the dormant assets scheme.

Energy Efficient Scotland: Improving energy efficiency in owner occupied homes

First Homes consultation

BSA responds to the MHCLG consultation on design and delivery of the First Homes scheme.

FCA regulated fees and levies: rates proposals 2020/ 2021

Our main concerns with these proposals, and the fees and levies policies in general, relate to cost control and to the lack of an appropriate fees tariff for building societies. Many points are mirro...

PRA regulatory fees and levies rates proposals, 2020-2021

Our main concerns relate to cost control and to the lack of an appropriate fees tariff for building societies.

Temporary financial relief for consumer credit borrowers

BSA broadly supports FCA measures

Direct marketing code of practice - ICO consultation

We set out our concerns about the draft code's potential impact on maturity communications and urge the ICO to liaise with the FCA.

FOS Budget 2020

Management expenses levy limit for the FSCS - proposals for 2020/ 2021

Our comments are brief and high level and reflect our concerns about the rising costs of operating the FSCS.

The Future Homes Standard: changes to Part L and Part F of the Building Regulations for new dwellings

FCA Quarterly Consultation No 26 - CP19/33

The BSA sets out its concerns regarding the FCA's proposed amendments to the guidance on the definition of a "Payment Account".

Implementing Basel 4 in the EU

We call for more systematic proportionality to reduce the unnecesssary burdens on small, non-complex banks, including most building societies.

Asset Encumbrance

The main proposals are reasonable, and will improve clarity and transparency.

Credit unions - PRA review of capital regime

We broadly welcome and support the review proposals

Financial Services Future Regulatory Framework Review

BSA calls for parity for mutuals, "think small first", and some legislative updating.

Making Home Ownership Affordable

The BSA response to the MHCLG Discussion Paper on shared ownership.

Guidance for firms on the fair treatment of vulnerable customers

Proportionality in EU banking regulation

Pillar 2 liquidity: PRA 110 reporting frequency threshold

Large building societies have confirmed they are able to report the PRA 110 on a daily basis in times of specific or market liquidity stress – but warn there could also be resource implications to suc...

Our response to HMRC consultation on maturing child trust funds - draft regulations

We support HMRC's move to ensure that maturing CTFs do not lose their tax advantaged status post-maturity. BSA and its members contributed to the response facilitated by industry group, TISA.

BSA responds to Financial Ombudsman Service funding proposals

New funding proposals from the Financial Ombudsman Service run counter to the principle of 'polluter pays' with more cost falling on those firms with fewer complaints. The BSA has responded to the om...

Decarbonisation of the UK Economy and Green Finance inquiry

Response to DP19/2 Intergenerational Differences Paper

BSA response to the FCA discussion paper on intergenerational differences between Baby Boomers, Gen X and millennials, and their differing financial outcomes.

Response to Building a Safer Future

BSA response to an MHCLG consultation proposing a new regulatory framework for building safety.

BSA response to FCA consultation on mortgage advice and selling standards

The BSA welcomes this consultation on current advice and selling standards. The aim of these proposals is to provide greater consumer choice and allow the development of further digital solutions.

Independent review of the Financial Reporting Council

In light of the series of recent accounting failures at large UK companies a review of the current regulatory arrangements is clearly overdue. We welcome this move. This is an opportunity to promot...

Our response to PRA fee rates proposals for 2019/ 2020

We argue for a more appropriate fees policy for mutuals. Treating building societies the same as banks ignores the differences in risk and business models.

BSA response to FCA/PRA changes to mortgage reporting requirements

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 ...

Pillar 2 liquidity: Updates to the framework

Our response focuses on HQLA and PRA 110, specifically timing and superequivalence aspects.

Resolvability Assessment Framework

The Affordable Housing Commission

BSA response to the Affordable Housing Commission

Response to HCLG Committee inquiry into Modern Methods of Construction (MMC)

BSA response to the Housing, Communities and Local Government Committee's inquiry into Modern Methods of Construction.

Reinvigorating Commonhold: The Alternative to Leasehold Ownership

BSA response to Law Commission consultation on reinvigorating commonhold.

Child Trust Funds - minor changes

We propose that by removing the requirement to provide the child’s address on the CTF annual statement, the safeguarding risk that could arise from it would be eliminated. Implementing system changes...

Fair Pricing in Financial Services

The BSA has submitted comments on the FCA's Discussion Paper 18/9 "Fair Pricing in Financial Services", which sets out a framework for assessing the fairness of price discrimination practices.

Financial Ombudsman Service: strategic plans and budget for 2019-2020

The BSA is pleased to respond to the consultation by the Financial Ombudsman Service on its strategic plans and budget for 2019/2020

The Bank's regulatory and supervisory approach on Brexit

Consumers' Access to Financial Services

BSA response to the Treasury Select Committee Inquiry

BSA response to MHCLG leasehold consultation

Liquidity reporting: FSA 047 and FSA 048

The proposed six-month extension of existing returns FSA 047 and FSA 048 is driven by problems with PRA 110. We therefore urge the PRA to delay implementation of this new return.

'Loyalty penalty' super-complaint

An overall observation is that, in a competitive market, prices and charges will inevitably vary from product-to-product and firm-to-firm. There is a limit to how far regulators or government should i...

Price discrimination in the cash savings market

We are urging the FCA to adopt a more targeted and proportional approach, focused on those consumers which it identifies as suffering substantial detriment and the firms which are responsible for that.

FCA DP18/5: A duty of care and potential alternative approaches

The clear conclusion is that, since there are ample rules, law and duties to protect UK financial service customers, there is no need for an additional duty of care. Therefore, we do not support the proposal.

Introducing the Directory: FCA CP 18/19

The BSA's response to FCA CP 18/19

Banks and Building Societies (Priorities on Insolvency) Order

Order introducing senior non-preferred debt for MREL purposes. BSA supports the SI's approach.

BSA response to DP01-18 Building the UK financial sector's operational resilience

Amending HMRC’s civil information powers

We point out the lack of independent oversight and lack of appeal for taxpayers. We also question the timing and process of the proposals.

Retail Banking Business Models Review

Authorised push payment fraud - extending to jurisdiction of the Financial Ombudsman Service

Fairness of variation terms in financial services consumer contracts under the Consumer Rights Act 2015

The BSA response to the FCA guidance consultation

Claims management: how we propose to regulate CMCs

We endorse the FCA’s underlying objectives for the CMC industry to be well regulated and properly focused on the fair treatment of customers. We believe that, despite significant resource constraints...

Credit risk mitigation

The BSA responded briefly to PRA's CP 6/18 on this subject.

Basel 4 - implementation in the EU

BSA submits response to Commission's brief exploratory consultation, and argues strongly for greater proportionality.

FCA Mission: Our Approach to Competition

The BSA responds to the FCA consultation

Cash ratio deposits

We argue the pool of contributors should be widened beyond deposit takers.

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 ...

FCA Mission: Our Future Approach to Consumers

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

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.

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.

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.

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.

FCA CP17/25: Extending the senior managers & certification regime to all FCA firms

The BSA's response to FCA CP17/25.

Pillar 2A capital requirements and disclosure

The BSA's response to PRA CP 12/17

Pillar 2 Liquidity - second consultation

The BSA's response to PRA CP 13/17

IPPR Commission on Economic Justice

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

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".

BSA response to tackling unfair practices in the leasehold market

Changes to the UK leverage ratio framework

MiFIR trading obligation

The BSA responded to ESMA's consultation on the implementation of the trading obligation under MiFIR.

Our response to FRED 67

We welcome any effort to improve, clarify and simplify accounting regulation.

FCA regulated fees and levies 2017/ 2018

We welcome the falls in some of the proposed fee rates. But we note with some disappointment the general increase in the regulator's costs.

BSA response to FCA CP17/11 Implementation of the revised Payment Services Directive (PSD2): draft Approach Document and draft Handbook changes

Refining the PRA's Pillar 2A capital framework

Our response to consultation on the third PPF levy triennium – 2018/19 to 2020/21

An industry scorecard for the regulated financial services sector is a good start but we have some concerns about its applicability to a typical building society. There are also question marks over ...

BSA response to Green Paper on Corporate Governance Reform

The BSA response, which highlights points of differentiation between our sector and PLCs and stresses the extent to which societies are already embracing high standards of corporate governance.

BSA response to 2017 Housing White Paper

BSA response to the Government's 2017 Housing White Paper, Fixing the Broken Housing Market.

Joint response to technical HMRC consultation on extending ISA tax advantages after death

Earliest possible start date is April 2018 ie the start of the tax year.

IFRS 9: changes to reporting requirements

We argue for a delay in implementation and reduced frequency.

PD and LGD estimation, and treatment of Defaulted Assets

FCA Mission consultation

This BSA paper responds to the FCA's consultation, Our Future Mission.

Widening access to savings to boost the UK's financial resilience: BSA responds to Help to Save consultation

BSA response to the Government's consultation on delivering a reformed Help to Save scheme.

Written evidence to the PCBS panel on tax, audit and accounting

The proposal for an EU-wide TIN

Swap clearing deadline extension

Strengthening capital standards: implementing CRD/ CRR, PRA CP 5/13

Strengthening accountability in banking - PRA CP 34/16

The BSA supports the PRA's proposals regarding the duty of responsibility and the application of the conduct rules to notified/standard NEDs, which are consistent with earlier representations made by the BSA.

Strengthening accountability in banking - FCA DP 16/4

This paper responds to FCA Discussion Paper 16/4 (the DP).

Strengthening accountability in banking - FCA CP 16/26

This response supports the proposals in, and comments on, FCA 16/26, which consults on guidance on how the FCA will enforce the 'duty of responsibility', which is now in force under the Bank of Englan...

Strengthening accountability in banking - FCA CP 16/27

This BSA response supports the proposal in FCA CP16/27 that 'standard' - sometimes called 'notified' - non-executive directors (NEDs) should be subject to the regulator's individual conduct rules and ...

Strengthening accountability in banking

BSA response to PRA CP1/16 and FCA CP 16/1, which consult on changes to rules and forms in the light of the Government's proposal to remove the requirement on relevant firms to report known or suspect...

Response to DCLG's Starter Homes Regulations technical consultation

In addition to concerns raised about the impact the scheme could have on other forms of affordable housing, our main point was around how the Starter Homes scheme's 20% discount should be operated.

Securitisation

Review of European Market Infrastructure Regulation

Retail CCDS - BSA response to FCA CP 14/23

Response to the BIS Call for Evidence: Terms & Conditions and Consumer Protection Fining Powers

The BSA response to the BIS call for evidence.

Regulatory treatment of accounting provisions, inc. interim and transitional arrangements

Regulatory references

This requirement could be a burden in some instances for societies.

Reform of the Credit Unions Sourcebook

Pillar 2 Liquidity

Our response to the latest draft regulations and guidance on FATCA implementation

Our response to the FSA's quarterly consultation paper no 34 (CP 12/ 27) - chapter 4, related parties

Our response to the FSA's consultation on removing the simplified ILAS firm scalar increase

Our response to the FSA's consultation on policy changes to fees and levies 2013/ 2014

Our response to the FRC's invitation to comment on the future development of FRS 102

Knowing that changes to the standard will be carried out only within a triennial review brings certainty to our sector. Building societies can plan with the assurance that FRS 102 is constant, and no...

Our response to the FCA Mortgage Credit Directive consultation

Our response to the BoE discussion paper, “A framework for stress testing the UK banking system”

Our response to the BoE consultation, A new sterling money market data collection and the reform of SONIA

We question the relevance of/ added value derived from all but the largest building societies’ data to the Bank of England’s stated objectives in this exercise.

Our responses to SRA consultations on proportionate regulation

Our response to second Basel consultation on revisions to the standardised approach to credit risk

While the second consultation represents a considerable improvement on the first, there remain areas of concern. There is a long way still to go before Basel arrives at a satisfactory framework to re...

Our response to Rethinking the UK financial services trade association landscape consultation

Our response to PSR CP14/1 A new regulatory framework for payment systems in the UK

Our response to PRA CP 1-15

Our response to HMRC's consultation on making tax digital

We question why such a monumental change is required at all for building societies when HMT/ HMRC designed the personal savings allowance to take out 95% of taxpayers of savings tax irrespective of fu...

Our response to HMRC consultation on the direct recovery of debt

Our response to HMRC consultation on implementing the United Kingdom’s agreements with the crown dependencies to improve international tax compliance

Our response to HMRC consultation on implementation of UK/ US FATCA agreement

Our response to FCA Quarterly Consultation No 7 CP 14/27

Our letter to HMT on its forthcoming review of the cash ratio deposit scheme

National Infrastructure Commission

The BSA's submission to the National Infrastructure Commission's call for evidence, focusing on the importance of investment in supporting infrastructure to overcome objections to new housebuilding de...

Our response to proposals on MRELs

We argue for changes. The application of MRELs through the partial transfer strategy to medium sized deposit-takers which have entered the current account market risks creating, through a massive cli...

Leverage Ratio Review - Interim Report

Joint letter to HMRC on plans to strengthen code of practice on taxation for banks

Interest rate risk in the banking book

Indirect Clearing under EMIR

Increasing mortgage risk weights under CRR Article 124

Implementation of the EU payment accounts directive

Impact of CRD 4 on financing the economy

Response to HMT draft innovation plan for financial services

In the BSA's response (marked confidential), we pointed out that regulation remained the biggest barrier for our members and while technology could potentially lessen this load in the future, in the ...

HMT consultation: Setting the strategy for UK payments

Help to Save: consultation on implementation

BSA response to HM Treasury's consultation

Help to Buy ISA - draft implemetation documents

Our brief response to joint consultation on FSCS management expenses levy limit 2016/ 17

We welcome the slight reduction in the budget but argue for more detail on "strategic change" expenditure.

FSA: Journey to the FCA

FCA consultation on strengthening accountability

FCA Competition Concurrency Guidance and Handbook Amendments

FCA call for input on PAD terms and definitions

Ensuring operational continuity in resolution - PRA DP 1/14

Draft amendments to FRS 102 - fair value hierarchy disclosures

We support the proposals.

CTF transfers to Junior ISAs

Our response to CMA Unfair Terms 2015

Changes to the Pension Protection Levy for 2017/18

We urge the PPF to amend its rules on the mortgage age variable for this triennium. Its rigid reliance on Companies House data disadvantages mutuals and other non-corporates.

Building Societies' Specialist Sourcebook

Our conclusion was that the revised Sourcebook as proposed in CP 12/16 is, overall, if sensibly and flexibly applied, a reasonable vehicle to achieve the PRA’s objectives on risk management, alignment...

BSA Response to FCA Consultation CP15/3 -BTL Mortgages, Implementing MCD

BSA response to chapter 4, FCA Quarterly Consultation CP15/19*

BSA response to BIS 7 day switching call for evidence

The BSA has responded to the Department for Innovation and Skills call for evidenced on improving the consumer landscape and quicker switching.

Basel review of IRB approaches for credit risk

The BSA has responded briefly to the BCBS CP on reducing variation in credit risk- weighted assets by constraining the use of internal model approaches. We also strongly support the preliminary input ...

Bank of England Bill

Bail-in : Response to HMT consultation May 2014

Our response to guidance consultation on pension obligation risk and the ICAAP

We argue that more consideration should be given to use of the accounting valuation to determine societies' own internal assessment of Pillar II pension obligation risk.

Our response to PRA consultation, CRD IV: liquidity, CP 27/14

Our response to HMT consultation on changes to the cash ratio deposit scheme

EU regulatory framework for financial services: Call for Evidence

A European Commission Consultation on Contract Law, Ministry of Justice

BIS: Enhancing Consumer Confidence by Clarifying Consumer Law: Consultation on the supply of goods, services and digital content

FSA CP 12/34: Regulatory Reform: FCA Handbook updates

The Law Commission and the Scottish Law Commission: Unfair Terms in Consumer Contracts: a new approach?

FSA CP12/35 The FCA's use of temporary product intervention rules

A Competition Regime for Growth: A Consultation on options for reform

Our response to FRED 51 - Draft amendments to FRS 102, Hedge Accounting

Our response to the Pension Protection Fund consultation on the second PPF Levy Triennium – 2015/16 to 2017/18

Our brief response to the consultation paper, Financial Services Compensation Scheme – Management Expenses Levy Limit 2015/16

Our response to the consultation, The PRA Rulebook: Part 2 – CP 25/ 14

Our Response to FCA Discussion Paper 14/2, Fairness of changes to mortgage contracts

FCA regulatory fees and levies: policy proposals for 2020/ 2021

BSA Response to FSA Consultation on FSCS Funding Review (CP 12-16).

21st Century Welfare - DWP consultation

BIS midata 2012 review and consultation

BSA responds to Government's consultations on banking reform and the future of building societies

CLG Committee inquiry into National Planning Policy consultation

Forbearance and Impairment Provisions FSA Guidance Consultation

FSA consultation paper, “Regulated fees and levies: Rates proposals 2012/13”, CP 12/3

FSA Mortgage Market Review DP 09/3

FSA Mortgage Market Review: Interest Only and Non deposit taking lenders

Higher SDLT for additional properties

Homes for Wales White Paper

Mortgage Market Review: Arrears Consultation CP10/2

Mortgage Market Review: Full package of reforms CP 11/31

Our letter to the US Internal Revenue on FATCA

Our response to BoE discussion paper on macroprudential tools

We support the paper's aims but argue against LTV and LTI ratios as they do not take individual circumstances into account.

Our response to EBA consultation on harmonised reporting (CP 50)

We argue for a delay in implementation and a more proportionate application.

Our response to EBA consultation on liquidity coverage and stable funding ratios

Our response to EBA consultation on reporting of leverage ratio

Our response to EBA's consultation on LE reporting (CP 51)

We argue for a later go-live date and a higher level for reporting exposures.

Our response to FSA guidance consultation on liquidity swaps

Our response to FSA quarterly consultation paper no 31, CP 11/27 - chapter 2

Read our response which addresses very minor changes to the liquidity regime

Our response to the Accounting Standards' Board's revised exposure drafts on the future of UK GAAP

On the whole, we welcome the revised draft. Our concerns remain, however, on the applicability of the proposals for EIR, impairment and financial instruments for smaller financial mutuals such as bui...

Our response to the FSA consultation on recovery and resolution plans

Our response to the FSA's annual consultation on changes to its regulatory fees and levies

Our response to the FSA's fees consultation CP 10/05

Our response to US Treasury and IRS on FATCA regulations

We continue to argue for wholesale exclusion from FATCA provisions for financial mutuals such as building societies. But we also suggest ways to make the current regulations more workable.

Parliamentary Commission on Banking Standards

Response to guidance consultation: senior asset and liability management committee practices, FSA GC 10/6

Support for Mortgage Interest: Informal Call for Evidence

Technical Reforms of Council Tax

The future of Right to Buy in Scotland

Our response to EC consultation on additional taxes for the financial sector

Our response to EC consultation on additional taxes for the financial sector. We argue these hit mutuals disproportionately hard.

Scottish Land and Buildings Transactions Tax

FOS Our 2022/23 plans and budget Consultation

The BSA welcomes the opportunity to respond to the FOS’s annual consultation on its plans and budget. While we remain supportive of its stated strategic priorities and the need to invest in a change p...

FCA Consultation CP21/13: A new Consumer Duty

The BSA has responded to the FCA's consultation paper outlining a proposed new Consumer Duty

HM Treasury: A New Approach to Financial Regulation: draft secondary legislation

FSA CP 12/37: The Financial Services Bill: Implementing market powers, decision making procedures and penalty policies

FSA CP12/30: Complaints against the regulators

FSA CP 12/24 Regulatory Reform: PRA and FCA regimes relating to aspects of authorisation and supervision

Equality Act 2010: Age Supplement to the Services, Public Functions & Associations Statutory Code of Practice - Consultation by the Equality and Human Rights Commission

CP 13/8: Publishing information about enforcement warning notices

CP13/10 - Detailed proposals for the FCA regime for consumer credit

PRA's approach to supervising liquidity and funding risks

We agree there should be no order in which firms use the BoE's liquidity facilities or draw down their own liquid asset buffers to meet a liquidity need.

Response to Private Shared Ownership consultation

BSA response to the Ministry's of Housing's call for proposals on private shared ownership.

BEIS Committee Energy Efficiency Inquiry

The BSA argues that the Government's targets for energy efficiency will be challenging but possible with a clear timetable. Any support packages for homeowners should be informed by learning from the ...

PRA CP23/18 Enhancing banks' and insurers' approaches to managing the financial risks from climate change

The BSA welcomes the PRA's focus on climate change but argue that data on losses emanating from climate change in the mortgage book is required before firms can build models and carry out stress-testi...

BSA Response to FCA CP16/16

BSA response to HMT's consultation on Public Financial Guidance

The BSA has responded to HMT's consultation on public financial guidance. The proposals concern the restructuring of the existing delivery model to create a new pensions guidance body and a new money ...

Draft Finance Bill 2016

The Building Societies Association's submission to the House of Lords Economic Affairs Finance Bill Sub-Committee.

EU Green Paper on consumer choice in retail financial services

See our response to the European Commission Green Paper on Retail Financial Services.

FSA CP12/30: Complaints against the regulators

Letter to the Law Commission on proposals to update the Land Registration Act 2002

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

Our comments on HM Treasury's draft implementation documents for Help to Buy ISA

Our response to the joint consultation, Strengthening accountability in banking: forms, consequential and transitional aspects, FCA CP 14/31 and PRA CP 28/14

Response to the FCA's Ageing Population discussion paper

The BSA has responded to the FCA Discussion Paper on an Ageing Population and Financial Services. We also contributed a chapter to the Discussion Paper.

Response to the Lords Economic Select Committee Inquiry into the UK Housing Market

The BSA has responded to the House of Lords Economic Select Committee's Inquiry into the UK Housing Market.

Strengthening Accountability in Banking

Our response to the EBA's draft guidelines on liquidity coverage ratio reporting

We support the representations made by our European partner, the European Association of Co-operative Banks. Our main concerns lie in proportionality, frequency and the calculation methodology.

CLG Select Committee on Housing for Older People

The BSA responded to the CLG Select Committee, highlighting our work on lending into retirement and desire to work with develops to increase the supply of suitable housing for older people.

BSA Response to Breathing Space call for evidence

BSA Repsonse to Public Financial Guidance Review: consultation on a single body

Our response to the Bank of England and Financial Services Public Bill Commitee

The BSA's response to the Bank of England Bill Committee.

BSA endorses the UK Money Markets Code

The BSA has formally endorsed the new Code, and we have encouraged all relevant members - i.e. who are UK Market Participants as defined in the Code - to work towards committing to, and embedding, the...

Regulatory reporting

We are disappointed that the “inconsistencies” between the templates in the policy statement and the XBRL taxonomy were not discovered at the time of publication.

PRA regulatory fees and levies rates proposals 2017/ 2018

We express concern at the implicit assumption that real costs always have to rise.

Our response to a further technical consultation on the apprenticeship levy

Information on the reclaim mechanism for employers in the devolved nations sought.

Management expenses levy limit for the FSCS, 2017/ 18

We argue for more detail on IT spend.

Transaction Monitoring Systems

The New Capital Adequacy Directive, CAD 3: The transposition of the new Basel Accord into EU legislation

Our response to further consultation on strengthening accountability in banking - FCA CP 15/5 and PRA 7/15

Restricting tax relief for banks’ compensation expenditure

Response to quarterly consultation paper no 27, FSA CP 11/1 (chapter 3 only)

Our response to PRA consultation on regulatory reporting of financial statements, forecast capital data and IFRS 9 requirements

We urge the PRA to use Brexit as an opportunity to review its regulatory reporting requirements, particularly for non-systemic institutions. FINREP through the back door is not the answer.

Regulatory reform: the PRA and FCA regimes for Approved Person (CP12/26)

Proposed amendment to the regulatory valuation of available-for-sale debt securities, chapter 3 of the FSA's quarterly consultation, CP 09/12

Our response to the Prudential Regulation Authority fees and levies: policy proposals for 2014/15, CP10/13

Our response to the PRA consultation paper on the PRA rulebook, CP 2/14

Our response to the PRA consultation paper, “Prudential Regulation Authority regulated fees and levies: rates proposals 2013/14”, CP 3/13

Our response to the liquidity proposals in FSA quarterly consultation 11/ 18 (no 30)

Our response to the latest draft regulations and guidance on FATCA implementation

HM Treasury consultation on the Financial Policy Committee’s housing policy tools

Our response to the FSA's QCP no 29, CP11/11, specifically chapter 4 - liquidity and chapter 9 - general provisions

Our response to the FSA’s consultation, Financial Services Compensation Scheme – management expenses levy limit 2013/14, CP 13/4

Our response to the FCA/ PRA consultation, “Financial Services Compensation Scheme – management expenses levy limit 2014/15”, FCA CP 14/1 and PRA 1/14

Our response to the FCA consultation "Payment Systems Regulation - Call for inputs"

Our response to the European Banking Authority’s consultation on draft implementing technical standards on additional liquidity monitoring metrics

Our response to Prudential Regulation Authority's occasional consultation paper, CP 8/13

Our response to PRA consultation on credit risk: IRB approaches, CP 4/13

Our response to HM Treasury's consultation 'Opening up UK payments'

Our response to HMRC consultation on strengthening the code of practice on taxation for banks

Our response to guidance consultation on updated code of practice between the external auditor and the FCA supervisor

Our response to FCA fees paper, “FCA regulated fees and levies: rates proposals 2013/14, CP 13/1

Our response to EBA discussion paper on draft standards on prudent valuation

Our response to EBA consultation on the minimum requirement for own funds and eligible liabilities, CP/ 2014/ 41

Our response to EBA consultation on the content of recovery plans

Our response to EBA consultation on draft ITS on supervisory reporting on forbearance and non-performing exposures

Our response to Basel Committee consultation on capital floors

Our response to Basel Committee consultation on revisions to the standardised approach to credit risk

Our response to an EBA consultation on credit risk adjustments

Our reponse to EBA consultation on RTS for additional liquidity outflows

Our question to the EBA on the scope of FINREP

Our high level response to the EBA discussion paper on a draft methodology for assessment of liquidity and funding risk under SREP

Our response to the FCA’s consultation paper, Regulatory fees and levies: policy proposals for 2014/15, CP 13/14

Our comments on Finance Bill 2015 – direct recovery of debts draft clauses

Liquidity Risk in the Integrated Prudential Sourcebook: A Quantitative Framework

Letter to the Law Commission on proposals to update the Land Registration Act 2002

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

Implementing the United Kingdom’s Agreements with the Crown Dependencies and Gibraltar to Improve International Tax Compliance

Effective internal audit in the financial services sector

Our response to the PRA consultation on disclosure of encumbrance

Compulsory purchase consultation

BSA response to EBA consultation on draft ITS on supervisory reporting on forbearance and non-performing exposures

BSA Autumn Statement submission

The BSA submission ahead of the Autumn Statement

BIS consultation on moving Land Registry operations to the private sector

We have set out a number of concerns with the proposal to have a private profit-maximising body operating the Land Registry, as this could lead to disruptions in the registration process and affect th...

Our response to a technical consultation on the Apprenticeship levy

More detail needed on how regulations will work in practice.

Industry Responses

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BSA responds to CP13/24 - securitisation

BSA Responds to CP2/25 proposals to increase threshold for leverage ratio framework

BSA responds to CP7/24, CP8/24 and CP9/24

Broadening access to financial advice for mainstream investments

BSA responds to MREL consultation

BSA responds to the Bank of England discussion paper on transitioning to a repo-led framework

BSA response to FCA CP25/11: Mortgage Rule Review

BSA response to HMT Common Bond Reform call for evidence

BSA response to PRA CP17/24 and FCA CP24/28 on operational resilience: operational incident and outsourcing and third party reporting

BSA Response to Treasury Committee Inquiry into the Lifetime ISA

Financial Ombudsman Service Our 2025/26 Plans and budget consultation

FOS & FCA Call for input on modernising the redress system

HMT Financial Services Growth & Competitiveness Strategy

Improving the home buying and selling process

Decarbonising Home Heating

PRA and FCA joint consultation on Remuneration Reform

Reforming the Energy Performance of Buildings Regime

Retrofitting our homes for a net zero future

Labour's new deal for leaseholders

BSA response to Law Commission consultation; Leasehold home ownership: buying your freehold or extending your lease.

Shared Ownership

Review of FCA requirements following the introduction of the Consumer Duty

Resolution assessments: amendments to reporting and disclosure dates

BSA Autumn Budget 2024 Submission

FOS Consultation on charging Claims Management Companies & other professional representatives

Common Reporting Standard Consultation

PRA's Approach to Policy

Recapitalisation - Enhancing the Special Resolution Regime

BSA Response to CP1/24 - FSCS MELL 2024/25

Strengthening protections for borrowers in financial difficulty

FPC affordability test consultation

The Appointed Representative regime

BSA response to CP21/34

Further proposals to support mortgage borrowers impacted by coronavirus

Regulation of insolvency practitioners, review of the regulatory landscape.

Mortgage customers: proposed changes to responsible lending rules and guidance

BSA response to HM Treasury breathing space scheme: consultation on a policy proposal.

Peer-to-peer and crowdfunding platforms

BSA response to FCA Mortgage Market Study: Interim Report MS16/2

BSA publishes submission to FCA Mortgages Market Study interim report

Public Financial Guidance

Spring Budget 2024: Helping First Time Buyers and Savers

CP9/23 The Bank of England's approach to enforcement: proposed changes and clarifications

Response to CP23/22 FCA Regulated Fees and Levies 2024/25

BSA Response to House of Lords Regulators Inquiry

Diversity & Inclusion in Financial Services

FSCS Electronic Transfer of Compensation

FRC Revisions to the Ethical Standard

BSA Response to CP15/23 Securitisation

Solvent Exit Planning for Non-Systemic Firms

Autumn Statement 2023: Helping First Time Buyers and Savers

PRA's Future Approach to Policy Making

GC23-2 FCA Guidance consultation on financial promotions on social media

FRC UK Corporate Governance Code consultation 2023

Reporting on regulatory capital: choices for assurance

Non-performing exposures - capital deduction

HMR consultation, "A bank levy banding approach"

Financial Reporting Council - Competition in the audit market

FCA Credit Information Market Study Interim Report - MS19/1.2

Implementation of the Basel 3.1 Standards

FCA regulated fees and levies: rates proposals for 2023/24

RICS cladding consultation

Money Advice Service and the coordination and provision of debt advice

The Strong and Simple Framework: Liquidity and Disclosure requirements for Simpler-regime firms

HM Treasury Call for Evidence: Senior Managers & Certification Regime

Our response to the PRA's Buy-to-let underwriting standards consultation

Bank of England requirements for a loan-level data collection for buy-to-let

CP7/23 - Regulated fees and levies: Rates proposals 2023/24

FOS Our 2023/24 plans and budget Consultation

Regulated fees and levies: Rate proposals 2023/2024

PRA Approach to supervising credit unions

Guidance for firms supporting borrowers impacted by the rising cost of living