Industry Responses

As well as proactively campaigning, the BSA frequently comments on consultative papers issued by the Financial Conduct Authority and Prudential Regulation Authority, and by Government departments such as the Treasury or the Department for Business, Innovation and Skills. 

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Recovery planning

These requirements appear to go above and beyond the Bank Recovery and Resolution directive.  We are particularly concerned by the "playbook" and "fire drills".

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MiFIR trading obligation

The BSA responded to ESMA's consultation on the implementation of the trading obligation under MiFIR.

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BSA endorses the UK Money Markets Code

The BSA has formally endorsed the new Code, and we have encouraged all relevant members - i.e. who are UK Market Participants as defined in the Code - to work towards committing to, and embedding, the new Code by the end of 2017.

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Regulatory reporting

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.

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Our response to FRED 67

We welcome any effort to improve, clarify and simplify accounting regulation.

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FCA regulated fees and levies 2017/ 2018

We welcome the falls in some of the proposed fee rates.  But we note with some disappointment the general increase in the regulator's costs.

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Our response to consultation on the third PPF levy triennium – 2018/19 to 2020/21

An industry scorecard for the regulated financial services sector is a good start but we have some concerns about its applicability to a typical building society.   There are also question marks over the scorecards for entities with a credit rating.

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PRA regulatory fees and levies rates proposals 2017/ 2018

We express concern at the implicit assumption that real costs always have to rise. 

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