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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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An overall observation is that, in a competitive market, prices and charges will inevitably vary from product-to-product and firm-to-firm. There is a limit to how far regulators or government should intervene in pricing practices within industries that are competitive, wellregulated and have a strong ombudsman service – and where firms have provided customers with all relevant information and there are no unfair barriers to changing products.
Order introducing senior non-preferred debt for MREL purposes. BSA supports the SI's approach.
The BSA's response to FCA CP 18/19
We point out the lack of independent oversight and lack of appeal for taxpayers. We also question the timing and process of the proposals.
The BSA response to the FCA guidance consultation
We endorse the FCA’s underlying objectives for the CMC industry to be well regulated and properly focused on the fair treatment of customers. We believe that, despite significant resource constraints, the Ministry of Justice has been a good regulator, but the time is right for the FCA to assume the role.
The BSA response to the FCA Consultation