We find no case for mandatory replacement of FSA 015 at this early stage.   Time is needed for IFRS 9 to bed in before any change is made to reporting.  What may look important now may not be once the full impact of the new standard has been felt. 2021 could be a more appropriate start date.  The uncertainties thrown up by Brexit could lead to building societies committing a lot of resource in a compressed timescale for a suite of returns that may ultimately be withdrawn/ substantially changed.  To make matters worse, the earliest the Bank of England will provide final rules is June 2017 – and without any supporting guidance for affected building societies. 

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