The BSA’s 43 member building societies are all predominantly funded by the retail savings of individuals, as required by the Building Societies Act. This is modestly supplemented, particularly at larger societies, by prudent use of wholesale funding from appropriate markets. Some of this is raised on a secured basis (covered bonds, repo, and use of  Bank of England “Red Book” facilities), and some on an unsecured basis (corporate and local authority deposits, interbank and intersociety lending, CDs and FRNs).

The main proposals in CP 24/19 are reasonable, and will improve clarity and transparency. The specific application to building societies looks, in our view, somewhat over-engineered in places, and could be cut back and simplified.

Read our full response here.