The BSA has responded to the FPC's assessment of bank capital requirements in our report "Getting the balance right: Calibrating capital to support growth, stability and homeownership."

In our response we argue that the FPC should more carefully consider the impact of its policies on mutuals and how that can impact business model and structural diversity which is in turn good for financial stability. We argue to remove elements of gold-plating in the UK framework, such as the leverage ratio buffers. We also argue that buffers are less usable for a mutual vs a shareholder bank given the more limited ability to rebuild buffers. Finally we include an example of the layering effect of capital and MREL requirements which mean that overall loss absorbing requirements for a low risk mortgage are around ten times the pillar 1 requirement, which does not feel proportionate and restrains growth and the sectors' ability to support the housing market.