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The voice of building societies
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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This response supports the proposals in, and comments on, FCA 16/26, which consults on guidance on how the FCA will enforce the 'duty of responsibility', which is now in force under the Bank of England and Financial Services Act 2016.
This BSA response supports the proposal in FCA CP16/27 that 'standard' - sometimes called 'notified' - non-executive directors (NEDs) should be subject to the regulator's individual conduct rules and to rule 4 of the senior conduct rules
We argue for a later implementation date and the development of a more proportionate approach to expected credit loss provisioning.
More detail needed on how regulations will work in practice.
The BSA submission ahead of the Autumn Statement
Knowing that changes to the standard will be carried out only within a triennial review brings certainty to our sector. Building societies can plan with the assurance that FRS 102 is constant, and not subject to regular change.
We urge the PPF to amend its rules on the mortgage age variable for this triennium. Its rigid reliance on Companies House data disadvantages mutuals and other non-corporates.
We question why such a monumental change is required at all for building societies when HMT/ HMRC designed the personal savings allowance to take out 95% of taxpayers of savings tax irrespective of future interest rate changes. Scanty detail makes it hard to provide meaningful feedback but the implication is clear - very high costs and much disruption for building societies.
We support the representations made by our European partner, the European Association of Co-operative Banks. Our main concerns lie in proportionality, frequency and the calculation methodology.
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