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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PRA CP23/18 Enhancing banks' and insurers' approaches to managing the financial risks from climate change

The BSA welcomes the PRA's focus on climate change but argue that data on losses emanating from climate change in the mortgage book is required before firms can build models and carry out stress-testing and scenario analysis. 

 

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BSA response to Law Commission consultation; Leasehold home ownership: buying your freehold or extending your lease.

The BSA welcome the Law Commission’s proposals which support governments recent work to simplify and make the leasehold process more fair for leaseholders.  The paper looks at simplifying the enfranchisement process.

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Consumers' Access to Financial Services

BSA response to the Treasury Select Committee Inquiry

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Liquidity reporting: FSA 047 and FSA 048

The proposed six-month extension of existing returns FSA 047 and FSA 048 is driven by problems with PRA 110. We therefore urge the PRA to delay implementation of this new return.  
 

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FCA DP18/5: A duty of care and potential alternative approaches

The clear conclusion is that, since there are ample rules, law and duties to protect UK financial service customers, there is no need for an additional duty of care.  Therefore, we do not support the proposal.

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Peer-to-peer and crowdfunding platforms

We agree with the spirit of the consultation which addresses a potential gap in protection for consumers choosing to apply for home finance via a Peer to Peer (P2P) platform. 

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Price discrimination in the cash savings market

We are urging the FCA to adopt a more targeted and proportional approach, focused on those consumers which it identifies as suffering substantial detriment and the firms which are responsible for that.

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'Loyalty penalty' super-complaint

An overall observation is that, in a competitive market, prices and charges will inevitably vary from product-to-product and firm-to-firm. There is a limit to how far regulators or government should intervene in pricing practices within industries that are competitive, wellregulated and have a strong ombudsman service – and where firms have provided customers with all relevant information and there are no unfair barriers to changing products.

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