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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BSA response to BIS 7 day switching call for evidence

The BSA has responded to the Department for Innovation and Skills call for evidenced on improving the consumer landscape and quicker switching.

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Basel review of IRB approaches for credit risk

The BSA has responded briefly to the BCBS CP on reducing variation in credit risk- weighted assets by constraining the use of internal model approaches. We also strongly support the preliminary input and comprehensive response from the EACB.

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BSA response to HMT's consultation on Public Financial Guidance

The BSA has responded to HMT's consultation on public financial guidance. The proposals concern the restructuring of the existing delivery model to create a new pensions guidance body and a new money guidance body.

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Bank of England requirements for a loan-level data collection for buy-to-let

The BSA responded to a 2016 Bank of England consultation on proposals for a loan level data collection for buy-to-let. The current threshold level for the buy-to-let data requirements is £20m of new buy-to-let lending per annum and the FCA is looking to introduce the new measures by July 2017.

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BIS consultation on moving Land Registry operations to the private sector

We have set out a number of concerns with the proposal to have a private profit-maximising body operating the Land Registry, as this could lead to disruptions in the registration process and affect the wider property market.

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Response to DCLG's Starter Homes Regulations technical consultation

In addition to concerns raised about the impact the scheme could have on other forms of affordable housing, our main point was around how the Starter Homes scheme's 20% discount should be operated. 

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Response to HMT draft innovation plan for financial services

 In the BSA's response (marked confidential), we pointed out that regulation remained the biggest barrier for our members and while technology could potentially lessen this load in the future, in the short term it remained a major burden on resources.

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Response to the FCA's Ageing Population discussion paper

The BSA has responded to the FCA Discussion Paper on an Ageing Population and Financial Services. We also contributed a chapter to the Discussion Paper.

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EU Green Paper on consumer choice in retail financial services

See our response to the European Commission Green Paper on Retail Financial Services.

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Our response to proposals on MRELs

We argue for changes.  The application of MRELs through the partial transfer strategy to medium sized deposit-takers which have entered the current account market risks creating, through a massive cliff effect at the boundary, a major barrier to competition in the current account market

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Our response to second Basel consultation on revisions to the standardised approach to credit risk

While the second consultation represents a considerable improvement on the first, there remain areas of concern.  There is a long way still to go before Basel arrives at a satisfactory framework to replace the current standardised regime.

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