Industry Responses

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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Our response to the FRC's invitation to comment on the future development of FRS 102

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.

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Changes to the Pension Protection Levy for 2017/18

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.

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Our response to HMRC's consultation on making tax digital

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.

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Our response to the EBA's draft guidelines on liquidity coverage ratio reporting

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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Our response to PRA consultation on regulatory reporting of financial statements, forecast capital data and IFRS 9 requirements

We urge the PRA to use Brexit as an opportunity to review its regulatory reporting requirements, particularly for non-systemic institutions.   FINREP through the back door is not the answer.

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Help to Save: consultation on implementation

BSA response to HM Treasury's consultation

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Building Societies' Specialist Sourcebook

Our conclusion was that the revised Sourcebook as proposed in CP 12/16 is, overall, if sensibly and flexibly applied, a reasonable vehicle to achieve the PRA’s objectives on risk management, alignment with risk appetite and reduction of crystallised risk.


 

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Letter to the Law Commission on proposals to update the Land Registration Act 2002

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

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Letter to the Law Commission on proposals to update the Land Registration Act 2002

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

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Our response to the PRA's Buy-to-let underwriting standards consultation

The BSA has responded to the Prudential Regulation Authority's (PRA) Buy-to-let underwriting standards consultation, which looks to introduce tighter underwriting standards for buy-to-let lending, in particular landlords with 4+ properties.

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