Today’s CRD scheme came into effect on the passing of the Bank of England Act some 20 years ago.  The scheme has not changed substantially since, despite shifts in the economic and regulatory landscape that have caused the Bank of England’s role to expand.  Missing opportunities for reform cannot continue indefinitely: they were lost in 2013 and again it seems, in 2018.   Now – and not 2023, the date of the next five-year review - is the time to address how to fund the Bank of England’s critical monetary policy and financial stability policy work.   Otherwise the scheme starts to look like another tax on the building society and bank sector.  A fee-based model seems the fairest, most efficient and most transparent solution.  We would be pleased to work with HM Treasury and the Bank of England on the development of such a mechanism.  

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