The BSA maintains its vocal, warm and consistent support for PRA’s overall Strong and Simple (“S&S”) initiative. We accept it will take some time to finalise and put in place, but we want PRA to have sufficient space and time to be able as far as possible to get the new regime right at first attempt. We support starting with the lowest of any tiers (i.e. smallest / simplest firms) first, though we remind PRA that what we will call “large but simple” firms also aspire to gain some benefits from the overall S&S initiative. We appreciate it is difficult to comment fully on definitions while policy content is still to come, but we endeavour to do so, constructively. The CP 5/22 proposals are broadly in line with what the BSA called for in our detailed response to DP 1/21, so we have no need to repeat previous arguments, which should be taken as read. We support PRA’s openness to using the FSMA-based waiver/modification procedure where appropriate, and we put forward a further instance where it might prove useful.
Read the full response here.