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by the following authors: 'Jeremy Palmer'

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Banks and Building Societies (Priorities on Insolvency) Order

Industry response,
Contact:
jeremy palmer,
Last updated:
03 October 2018

The BSA is pleased to respond to the Treasury’s consultation on the draft  Statutory Instrument (SI) that will implement the EU’s Creditor Hierarchy Directive (CHD) in the UK. The BSA has strongly advocated the CHD and its fast-tracking, given its importance for larger buildi...

The Bank's regulatory and supervisory approach on Brexit

Industry response,
Contact:
jeremy palmer,
Last updated:
02 January 2019

The BSA broadly welcomed the general approach in these CPs but cautioned that in view of the resulting increased fragmentation and opaqueness of regulatory material, an authoritative consolidation should be undertaken in due course. Read the full response here.

Resolvability Assessment Framework

Industry response,
Contact:
jeremy palmer,
Last updated:
04 April 2019

The BSA supports the principle of a transparent RAF, and commends the Bank's publication of the Purple Book . Implementation of the RAF should be as efficient as possible, maximising use of / reliance on systems, processes or capabilities already in place or in train, and mi...

Proportionality in EU banking regulation

Industry response,
Contact:
jeremy palmer,
Last updated:
01 July 2019

The tide of opinion among industry practitioners, academics and many regulators is turning ever more strongly in favour of greater proportionality. In this paper , we draw on insights from landmark studies in the European space, such as the EBA Banking Stakeholder Group’s 20...

Financial Services Future Regulatory Framework Review

Industry response,
Contact:
jeremy palmer,
Last updated:
21 October 2019

The BSA has always supported fair, effective and proportionate regulation - and, as circumstances change, the detail of the framework needs periodic review. We support the sensible design principles for the Review, and  call for parity of treatment for mutuals, and better pro...

Credit unions - PRA review of capital regime

Industry response,
Contact:
jeremy palmer,
Last updated:
23 January 2020

The BSA (principally on behalf of its six [1] large credit union members) broadly welcomes and supports the review of the credit union capital regime proposed by the PRA in CP 28/19. We particularly welcome the immediate effect on our members of the graduated approach; the d...

Asset Encumbrance

Industry response,
Contact:
jeremy palmer,
Last updated:
23 January 2020

The BSA’s 43 member building societies are all predominantly funded by the retail savings of individuals, as required by the Building Societies Act. This is modestly supplemented, particularly at larger societies, by prudent use of wholesale funding from appropriate markets. ...

Implementing Basel 4 in the EU

Industry response,
Contact:
jeremy palmer,
Last updated:
23 January 2020

As we explained in detail in our April 2018 response, what is most needed now is far more systematic proportionality in the application of Basel-derived rules to small, non-complex banks. As is well known, the Basel Agreements apply formally only to “Basel banks” – large, int...

Credit unions

Page,
Contact:
jeremy palmer,
Last updated:
15 August 2019

This page is designed as a landing page for staff and directors of BSA member credit unions to help access BSA and relevant external resources via signposting and links. Using the BSA website Remember that the website has public and members-only areas, and you need to be ...

Pillar 2A: Reconciling capital requirements and macroprudential buffers

Industry response,
Contact:
jeremy palmer,
Last updated:
30 April 2020

We challenged the unfair advantage conferred by the PRA's offsetting  proposals on banks, compared with both large societies that are leverage-constrained, and smaller societies with little or no variable Pillar 2A to offset. Read the full response  here.

Transposition of BRRD 2 in the UK

Industry response,
Contact:
jeremy palmer,
Last updated:
11 August 2020

BSA comments briefly on BRRD 2 transposition proposals, inter alia challenging the potential freezing of FSCS-covered deposits under the BRRD 2 moratorium power : we argued that post Brexit this was both unnecessary and undesirable in the UK. Read the full response here.

CRD V Implementation in the UK

Industry response,
Contact:
jeremy palmer,
Last updated:
19 August 2020

BSA very briefly responded to the Treasury's consultation on CRD V implementation, inter alia supporting the continued exemption of credit unions. Most of the CP's content did not concern BSA members.See the full response here.