We are pleased to have the opportunity to provide feedback on this occasional consultation paper.  We have no comment on the detail of the minor changes proposed.  But we are disappointed that the “inconsistencies” between the templates in the policy statement and the XBRL taxonomy were not discovered at the time of publication.  Although it is not their fault, regulated firms such as building societies bear the cost of late system changes.  

It was, however, helpful that May’s Regulatory Digest indicated that firms should instruct their vendors to prepare their systems to report forecast capital data in monetary values for PRA 101-103 and PRA 108 in units rather than thousands from 1 October 2017, when the requirements take effect.  The Digest also advised firms of this consultation.

While we understand why the PRA had to issue a consultation on these minor changes, we urge the regulator to find other, less cumbersome (and less costly to firms) ways to achieve its aims in future.