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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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The BSA argues that the Government's targets for energy efficiency will be challenging but possible with a clear timetable. Any support packages for homeowners should be informed by learning from the failure of the Green Deal.
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.
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.
BSA response to the Treasury Select Committee Inquiry
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.
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.
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.
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.