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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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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.
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.
The BSA has responded to the FCA's Call for Input on Open Finance, which looks to bring Open Banking data standards to a wider range of financial products and services.
BSA response to the APPG
Industry calls for clarification on onerousness.
BSA supports continued CRD exemption for credit unions
BSA challenges potential freezing of customer deposits under BRRD 2 moratorium power
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.
The BSA response to the Government consultation paper on expanding the dormant assets scheme.
BSA response to energy efficiency inquiry
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.