The BSA (principally on behalf of its six[1] large credit union members) broadly welcomes and supports the review of the credit union capital regime proposed by the PRA in CP 28/19. We particularly welcome the immediate effect on our members of the graduated approach; the delinking of capital requirements from both membership numbers and “additional activities”; and the tougher approach to weaker small credit unions with capital below 5%. We have a few other detailed comments, and we also commend the PRA for having undertaken proper cost benefit analysis in CP 28/19. Read our full response here.