Our response to the liquidity proposals in FSA quarterly consultation 11/ 18 (no 30)


The Building Societies Association represents mutual lenders and deposit takers in the UK including all 48 UK building societies. Mutual lenders and deposit takers have total assets of over £365 billion and, together with their subsidiaries, hold residential mortgages of almost £235 billion, 19% of the total outstanding in the UK. They hold more than £245 billion of retail deposits, accounting for 22% of all such deposits in the UK. Mutual deposit takers account for about 35% of cash ISA balances. They employ approximately 50,000 full and part-time staff and operate through approximately 2,000 branches.


We are pleased to comment on the liquidity chapter in the quarterly consultation paper:

FSA quarterly consultation CP 11/18 (no) - chapter 4

Q4.1 Do you agree with our proposal to amend BIPRU 12.6.7R to include charities?

We agree that this will result in a simplified and consistent treatment of charity deposits in both the calculation of the simplified buffer and reporting lines within FSA 047 and FSA 048.

Q4.2 Do you agree with our proposal to amend BIPRU 12.7.9R and 12.7.10G?

We welcome the proposal to amend BIPRU 12.7.10G so that assets held at a central bank in excess of the minimum amount of collateral required, and which can be withdrawn by a firm without restriction, can be recognised as unencumbered.

Q4.3 Do you agree with our proposal to amend SUP 16 Annex 25G to clarify reporting requirements under FSA048?

We do.

Q4.4 Do you agree with the cost benefit analysis?

We consider that the costs associated with these minor changes are low.