The BSA supports the principle of a transparent RAF, and commends the Bank's publication of the Purple Book. Implementation of the RAF should be as efficient as possible, maximising use of / reliance on systems, processes or capabilities already in place or in train, and minimising any duplication of effort. We advocate the "substantive gap" approach. Nor do we agree with the Bank / PRA's proposals for disclosure which we consider to be a high risk experiment.

Read our full response here