Industry response

Our response to the Pension Protection Fund consultation on the second PPF Levy Triennium – 2015/16 to 2017/18

Proposals drawn up too hastily without consideration for building societies

Introduction

The Building Societies Association represents mutual lenders and deposit takers in the UK including all 45 UK building societies.  Building societies have total assets of nearly £330 billion and, together with their subsidiaries, hold residential mortgages of over £230 billion, 18% of the total outstanding in the UK.  They hold over £230 billion of retail deposits, accounting for 19% of all such deposits in the UK.  Building societies account for about 28% of all cash ISA balances.  They employ approximately 39,000 full and part-time staff and operate through approximately 1,600 branches.

Summary

These proposals appear to have been drawn up hastily with too short a response time, too limited a circulation and crucially, without any consideration for sectors such as building societies.     

Discussion

The building society sector does not appear to have been adequately considered when developing the new methodology for assessing PPF levies. The templates used for the accounting information held on the Experian system are for a typical manufacturing company and as such, the format does not lend itself to financial services accounts in any meaningful way. To compound this, there does not appear to be an appetite at present for Experian to obtain information automatically for building society accounts from the Financial Conduct Authority (as building society accounts are not filed at Companies House).

Individual societies have been asked to key in manually their financial information to a spreadsheet.  But this spreadsheet is in the manufacturing format mentioned above.  This makes it very difficult to provide any meaningful data because of the very different format of financial services accounts.  

Most building societies have to date been unable to access any meaningful financial information on the portal to assess their levy score.  We therefore do not believe the consultation period has been long enough for everyone to respond as fully - or at all - as they would have liked.

Members and associates can find more in the policy brief on the PPF levy.