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 CP29/19 Operational resilience: Impact tolerances for important business services

We support proposals set out in the consultation paper to strengthen operational resilience, but we ask for further clarification and guidance on some specific areas.

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Outsourcing and third party risk management

We urge the PRA to review all its deadlines, particularly the one for the review of legacy outsourcing agreements, which we believe should be extended until at least 2023.   This is especially important if the prudential context element is going to draw third party arrangements into the material outsourced classification.  

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CRD V Implementation in the UK

BSA supports continued CRD exemption for credit unions

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Transposition of BRRD 2 in the UK

BSA challenges potential freezing of customer deposits under BRRD 2 moratorium power

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FCA Guidance Consultation on branch and ATM closures

In GC20/2, FCA sets out planned guidance for banks, building societies and credit unions to follow when planning closures of branches or ATMs or converting ATMs from free to customer to fee-charging.

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Government consultation on expanding the dormant assets scheme

The BSA response to the Government consultation paper on expanding the dormant assets scheme.

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Environmental Audit Committee energy efficiency inquiry

BSA response to energy efficiency inquiry

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FCA regulated fees and levies: rates proposals 2020/ 2021

Our main concerns with these proposals, and the fees and levies policies in general, relate to cost control and to the lack of an appropriate fees tariff for building societies.  Many points are mirrored in our response to the PRA’s fees consultation.  

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PRA regulatory fees and levies rates proposals, 2020-2021

Our main concerns relate to cost control and to the lack of an appropriate fees tariff for building societies.

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First Homes consultation

BSA responds to the MHCLG consultation on design and delivery of the First Homes scheme.

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