We welcome the opportunity to comment on this consultation. It raises important issues and identifies themes which resonate with the BSA and our members. As building societies fall within the current definition of “public interest entities” (PIEs), they are within scope of many of the proposals.
We would like to see a more holistic review of the scope of such requirements. In particular, we consider there to be a strong case for rationalisation and applying proportionality to the requirements currently imposed on smaller entities. The definition of a PIE needs to be drafted more tightly so it does not inadvertently catch “lower risk” entities in a level of unnecessary bureaucracy. Brexit presents opportunities to shape our domestic framework to meet the needs of UK entities and market participants and it is disappointing that the BEIS consultation does not contemplate this. Happily, there is still time for this to be addressed, prior to wider rollout of the BEIS proposals and we urge strongly that the opportunity is taken to do so.
Click here to read our full response.
Click here to read our open letter to the secretary of state for business, energy and industrial strategy, Kwasi Kwarteng.
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