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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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Appropriate and proportionate regulation is key to the long term future of the UK financial services sector. That the costs are paid for by the firms which benefit from this regulation is not disputed. Concerns arise where there are hints of a move away from the “polluter pays” principle.
We argue for a more appropriate fees policy for mutuals. Treating building societies the same as banks ignores the differences in risk and business models.
Our response focuses on HQLA and PRA 110, specifically timing and superequivalence aspects.
BSA response to the Affordable Housing Commission
BSA response to the FCA/PRA's to the FCA/PRA's consultation on changes to mortgage reporting requirements. We made the following recommendations.
* Expand the data fields in PSD007 to better capture internal product transfers and use this for smaller firms up to an annual gross mortgage-lending limit of £100m
* Extend the time period for firms to adopt the new reporting processes from 12 months to 18 months of publication of the final rules
* Ensure the Gabriel test environment is built and fully functional in tandem with publication of the final rules.
BSA response to Law Commission consultation on reinvigorating commonhold.
We propose that by removing the requirement to provide the child’s address on the CTF annual statement, the safeguarding risk that could arise from it would be eliminated. Implementing system changes and process controls mitigates the risk but does not eliminate it completely.
BSA response to the Ministry's of Housing's call for proposals on private shared ownership.
The BSA has submitted comments on the FCA's Discussion Paper 18/9 "Fair Pricing in Financial Services", which sets out a framework for assessing the fairness of price discrimination practices.