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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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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.
These proposals present significant complexities to mortgage lenders and would mean significant disruption to existing systems and processes which work well for the benefit of customers.
The BSA is pleased to respond to the consultation by the Financial Ombudsman Service on its strategic plans and budget for 2019/2020
BSA response to the Housing, Communities and Local Government Committee's inquiry into Modern Methods of Construction.
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.