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The 'Basel 4' reviews – storm in teacup or end of the world?

Newsbite,
Contact:
jeremy palmer,
Last updated:
29 September 2016

Every now and again you will read some press comment about bad things expected to result from the current set of “Basel reviews”. A good example – a real corker – was this from early 2015: “Secretive bank watchdog could slam door on first-time buyers” and referenced a “secreti...

Bail-in : Response to HMT consultation May 2014

Industry response,
Contact:
jeremy palmer,
Last updated:
28 January 2016

See our response to this consultation here .

Bank of England Bill

Industry response,
Contact:
jeremy palmer,
Last updated:
14 September 2015

The BSA welcomes the Government’s commitment to achieving strong, sustainable and balanced growth that is more evenly shared across the country and between industries. BSA members all have their main operational headquarters away from the City of London, and are a significant ...

Basel review of IRB approaches for credit risk

Industry response,
Contact:
jeremy palmer,
Last updated:
23 June 2016

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 strongly support the preliminary input and comprehensive response from the EACB. We caution that the BCBS' proposals have...

Building Societies' Specialist Sourcebook

Industry response,
Contact:
jeremy palmer,
Last updated:
04 July 2016

The BSA welcomed the opportunity to respond to PRA’s CP 12/16, revising Supervisory Statement SS 20/15, which is the document corresponding to the former Building Societies’ Specialist Sourcebook, and appreciates the early engagement BSA members have had with the relevant P...

Ensuring operational continuity in resolution - PRA DP 1/14

Industry response,
Contact:
jeremy palmer,
Last updated:
06 January 2015

The Building Societies Association (BSA) welcomes the opportunity to respond, briefly, to DP 1/14. Our comments mainly address the DP’s Question 1, on scope, and are provided from the perspective of BSA members, who will generally be external users of critical shared payme...

FSA consultation paper, “Regulated fees and levies: Rates proposals 2012/13”, CP 12/3

Industry response,
Contact:
jeremy palmer,
Last updated:
23 January 2013

Introduction The Building Societies Association represents mutual lenders and deposit takers in the UK including all 47 UK building societies. Mutual lenders and deposit takers have total assets of over £375 billion and, together with their subsidiaries, hold resi...

Impact of CRD 4 on financing the economy

Industry response,
Contact:
jeremy palmer,
Last updated:
08 October 2015

We welcome this initiative from Commissioner Hill and his team at the new DG FISMA, going beyond the narrow remit in CRD 4, asking the right questions, setting the right tone of enquiry and openness, not imprisoned by past decisions. We particularly welcome the material on pro...

Increasing mortgage risk weights under CRR Article 124

Industry response,
Contact:
jeremy palmer,
Last updated:
08 October 2015

The BSA is pleased to contribute to the EBA’s consultation  : as all our members are specialised residential mortgage lenders, the majority using the standardised approach, this matter is of great importance to us. For that reason, we concentrate in this response on  RWs for l...

Indirect Clearing under EMIR

Industry response,
Contact:
jeremy palmer,
Last updated:
17 December 2015

The BSA has responded to ESMA's consultation on indirect clearing primarily from the perspective of smaller building societies who already experience difficulty in securing cost-effective clearing services for OTC derivatives. We repeat our call for both short-term and longer-...

Interest rate risk in the banking book

Industry response,
Contact:
jeremy palmer,
Last updated:
14 September 2015

The Building Societies Association provides this brief response to the BCBS consultation. (Read the full response here .) The BSA’s members, the 44 UK building societies, all experience interest rate risk in the banking book (IRRBB,) though none is a “Basel bank” – i.e....

Our response to PRA CP 1-15

Industry response,
Contact:
jeremy palmer,
Last updated:
20 April 2015

Overview The BSA welcomes the opportunity to comment on the PRA’s proposals for Pillar 2. We agree that updating is needed in light of both CRD 4 and the EBA’s guidelines on SREP. The BSA particularly supports two features of the CP proposals:         (i) realign...

Pillar 2 Liquidity

Industry response,
Contact:
jeremy palmer,
Last updated:
11 August 2016

We welcome this consultation, and the PRA’s engagement with BSA members on this subject at a meeting on 22 June. We appreciate that the Pillar 2 issues are being spread across 2 CPs. We agree that final decisions on the whole package should be taken in the round, after the ...

Reform of the Credit Unions Sourcebook

Industry response,
Contact:
jeremy palmer,
Last updated:
06 October 2015

The BSA responded to this important consultation on behalf of its three major credit union members - No.1 CopperPot and Capital Credit Unions which are full members, and Glasgow Credit Union which is an associate member. We concentrated in this response on those items within t...

Regulatory treatment of accounting provisions, inc. interim and transitional arrangements

Industry response,
Contact:
jeremy palmer,
Last updated:
12 January 2017

We responded to a pair of Basel papers prompted by ECL provisioning under IFRS 9.The discussion paper  DP 385 looks at revising the future regulatory capital treatment of accounting provisions - read the BSA response here . The consultative paper CP 386 looks at interim and t...