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by the following authors: 'Jeremy Palmer'

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Retail CCDS - BSA response to FCA CP 14/23

Industry response,
Contact:
jeremy palmer,
Last updated:
02 February 2015

The BSA broadly welcomed FCA's proposals for the retail distribution of mutual shares such as CCDS (Core Capital Deferred Shares ), but calls for the new rules to be finalised quickly, and for the ceiling on individual investor holdings to be raised from 5 % to 10% of net ...

Review of European Market Infrastructure Regulation

Industry response,
Contact:
jeremy palmer,
Last updated:
18 August 2015

The BSA has responded to the Commission's 21 May consultation on the 2015 review of EMIR, calling for an exemption for smaller financial counterparties from the mandatory clearing obligation. Read the full response here.

Securitisation

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

The BSA is pleased to respond to the Commission’s consultation on securitisation, part of its wider work towards a Capital Markets Union outlined in the Green Paper. We welcome the emphasis in the foreword to the Green Paper on jobs and growth, and that capital markets should ...

Securitisation

Industry response,
Contact:
jeremy palmer,
Last updated:
01 March 2013

Read the BSA's  full response  to the Basel Committee's consultation on securitisation, from March 2013.

Securitisation

Industry response,
Contact:
jeremy palmer,
Last updated:
01 July 2014

Read the BSA's full response to the joint consultation on securitisation from the Bank of England and the European Central Bank

Swap clearing deadline extension

Industry response,
Contact:
jeremy palmer,
Last updated:
15 November 2016

ESMA has correctly summarised the key difficulties in relation to the clearing obligation. The position stated in paragraphs 11 to 15 exactly reflects the experience of our medium sized and smaller members. But we also draw ESMA’s attention to wider problems affecting small ...

PD and LGD estimation, and treatment of Defaulted Assets

Industry response,
Contact:
jeremy palmer,
Last updated:
14 February 2017

The BBA, BSA and CML have submitted a joint response to a technical consultation from the European Banking Authority on PD and LGD estimation, and the treatment of Defaulted Assets, under the Internal Ratings Approach. Read the full response here .

Refining the PRA's Pillar 2A capital framework

Industry response,
Contact:
jeremy palmer,
Last updated:
31 May 2017

The BSA's response to PRA's CP 3/17 broadly welcomes the PRA's proposals - which should help redress the current disadvantage most building societies and smaller banks experience with their Pillar 1 capital requirements. A modest but useful move in the right direction - read ...

BSA endorses the UK Money Markets Code

Industry response,
Contact:
jeremy palmer,
Last updated:
18 July 2017

The Money Markets Committee of the Bank of England published this new voluntary Code, covering the UK's wholesale money markets, in April 2017. The Code was drawn up by a sub-committee of market practitioners, including a representative from the building society sector. The B...

MiFIR trading obligation

Industry response,
Contact:
jeremy palmer,
Last updated:
09 August 2017

The BSA supports ESMA's proposals to align the phasing in of the MiFIR  trading obligation with the application dates for the EMIR clearing obligation. We also point out that the proposed exemption for very small financial counterparties from the clearing obligation (under th...

Changes to the UK leverage ratio framework

Industry response,
Contact:
jeremy palmer,
Last updated:
13 September 2017

We welcome the formalisation of the exclusion of central bank deposits from the exposure measure, but we do not support the accompanying recalibration of the leverage ratio minimum to 3.25%, which we regard as premature at this stage, and which could have unintended adverse c...

Pillar 2 Liquidity - second consultation

Industry response,
Contact:
jeremy palmer,
Last updated:
09 October 2017

The BSA supports robust and effective liquidity requirements, whether under Pillar 1 or Pillar 2, to ensure the safety and soundness of our members, and thereby the protection of their customers. Read the full response .

Pillar 2A capital requirements and disclosure

Industry response,
Contact:
jeremy palmer,
Last updated:
09 October 2017

We welcome the opportunity to respond briefly to PRA’s CP 12/17. We are content with the move from ICG to a formal P2A requirement set under section 55 of FSMA. The approach to solo Pillar 2A requirements looks reasonable. But we think PRA has not adequately made the case for...

Basel 4 - implementation in the EU

Industry response,
Contact:
jeremy palmer,
Last updated:
12 April 2018

The European Commission has held a very brief (4 week) exploratory consultation on the implementation in the EU of the revised framework resulting from the Basel 4 reviews. The BSA has responded directly to this consultation, as well as contributing to and supporting the coll...

Credit risk mitigation

Industry response,
Contact:
jeremy palmer,
Last updated:
14 May 2018

The BSA responded briefly to PRA's CP 6/18 on this subject. Our main interest is in mortgage insurance, and our response concentrates on this. Read the full response here.