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by the following authors: 'Elaine Morton'

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HM Treasury: A New Approach to Financial Regulation: draft secondary legislation

Industry response,
Contact:
elaine morton,
Last updated:
21 December 2012

Introduction 1. The Building Societies Association (BSA) 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, hol...

Our response to FCA Quarterly Consultation No 7 CP 14/27

Industry response,
Contact:
elaine morton,
Last updated:
13 January 2015

The BSA response to FCA Quarterly Consultation No 7 CP 14/27    

Response to the BIS Call for Evidence: Terms & Conditions and Consumer Protection Fining Powers

Industry response,
Contact:
elaine morton,
Last updated:
25 April 2016

The BSA response to the BIS call for evidence. The overriding point we make in this response is that financial services firms are already highly conduct-regulated by the Financial Conduct Authority (FCA) in the areas covered by the call for evidence. Read the full response ...

Strengthening accountability in banking

Industry response,
Contact:
elaine morton,
Last updated:
04 February 2016

This BSA response supports the proposals in, and comments on, PRA CP1/16 and FCA CP 16/1, which consult on changes to rules and forms in the light of the Government's proposal to remove the requirement on relevant firms to report known or suspected breaches of conduct rules. ...

Strengthening accountability in banking - FCA CP 16/27

Industry response,
Contact:
elaine morton,
Last updated:
03 January 2017

This BSA response supports the proposal in FCA CP16/27 that 'standard' - sometimes called 'notified' - non-executive directors (NEDs) should be subject to the regulator's individual conduct rules and to rule 4 of the senior conduct rules. The FCA's proposal aligns with the ...

Strengthening accountability in banking - FCA CP 16/26

Industry response,
Contact:
elaine morton,
Last updated:
03 January 2017

This response supports the proposals in, and comments on, FCA 16/26, which consults on guidance on how the FCA will enforce the 'duty of responsibility', which is now in force under the Bank of England and Financial Services Act 2016. The BSA consistently opposed the propos...

Strengthening accountability in banking - FCA DP 16/4

Industry response,
Contact:
elaine morton,
Last updated:
03 January 2017

This paper responds to FCA Discussion Paper 16/4 (the DP). The BSA appreciates the fair and open way in which the FCA has discussed the competing arguments behind the possibility of specifically allocating overall responsibility for the management of the legal function to a se...

Strengthening accountability in banking - PRA CP 34/16

Industry response,
Contact:
elaine morton,
Last updated:
03 January 2017

This response provides comments on PRA CP 34/16 (the CP), which deals with - the PRA's expectations on the duty of responsibility, the application of the conduct rules to notified/standard NEDs, and a range of proposed technical amendments. The BSA supports the PRA's p...

The Law Commission and the Scottish Law Commission: Unfair Terms in Consumer Contracts: a new appro

Industry response,
Contact:
elaine morton,
Last updated:
22 October 2012

Introduction 1. The Building Societies Association (BSA) 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, hol...

FCA Mission consultation

Industry response,
Contact:
elaine morton,
Last updated:
23 January 2017

This BSA paper responds to the FCA's consultation, Our Future Mission.  Our key points are as follows - Fewer, stronger rules that are properly enforced Coherent consumer protection Stable regulatory structures and requirements Constructive engagement on risk and regulat...

FCA CP17/25: Extending the senior managers & certification regime to all FCA firms

Industry response,
Contact:
elaine morton,
Last updated:
27 October 2017

The BSA is pleased to respond to FCA CP17/25.  Our key comments are as follows; the BSA -  supports the extension of a senior managers and certification regime to the other regulated financial services sectors; and emphasises the importance of fairness, consistency and prop...

FCA Mission: Our Future Approach to Consumers

Industry response,
Contact:
elaine morton,
Last updated:
29 January 2018

Executive summary: Consumer responsibility (question 1) : We note and support the FCA’s continued acknowledgement that  consumers have responsibilities, but we appreciate the fact that there are circumstances where consumers cannot be expected to take responsibility. We wo...

FCA Mission: Our Approach to Competition

Industry response,
Contact:
elaine morton,
Last updated:
09 March 2018

Broadly speaking, our view is that UK financial services has good levels of competition across core areas, but competition is not as strong in certain niches (eg payday and SME lending) or elements (eg National Savings and Investments, some price comparison websites, and prud...

Claims management: how we propose to regulate CMCs

Industry response,
Contact:
elaine morton,
Last updated:
31 July 2018

Summary It is important for claims management companies to be regulated as strongly as currently regulated financial services firms are.  It is clear that consumers can suffer at the hands of a currently regulated firm and of a claims management company if the business i...

Fairness of variation terms in financial services consumer contracts under the Consumer Rights Act 2

Industry response,
Contact:
elaine morton,
Last updated:
21 August 2018

You can download the response here .