Industry response

Banks and Building Societies (Priorities on Insolvency) Order

BSA response to HMT consultation on CHD implementation

The BSA is pleased to respond to the Treasury’s consultation on the draft  Statutory Instrument (SI) that will implement the EU’s Creditor Hierarchy Directive (CHD) in the UK. The BSA has strongly advocated the CHD and its fast-tracking, given its importance for larger building societies in meeting their MREL obligations at a more reasonable cost. We appreciate the Treasury’s support in the European Council for fast-tracking CHD and ( in response to Q1) we support the Treasury’s general approach to implementation in the draft SI. Our detailed responses  to the other consultation questions follow. We are grateful for rapid input both from our larger members contemplating  MREL instrument issuance, and from leading market practitioners.

Read the full response here.