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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...
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...
Introduction The Building Societies Association of the United Kingdom (BSA) is pleased to respond to the Committee’s consultation on revisions to the standardised approach to credit risk. The BSA represents all 44 UK building societies. Building societies have total ass...
Introduction The Building Societies Association of the United Kingdom (BSA) is pleased to respond to the Committee’s consultation on the design of a framework of capital floors based on standardised approaches. The BSA represents all 44 UK building societies, of which o...
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.
Much of the content of CP 5/13 is sensible and welcome – we give several examples in our full response. But some of the policy choices proposed by PRA are unwelcome and, in our view, unjustified – and in certain instances renege on clear commitments given by the FSA in Oct...
Speaking at the BSA’s Annual lunch, BSA Chairman, Dick Jenkins, outlined his views on Brexit and launched a new BSA housing report which recommends ten actions aimed at bringing new housebuilding technologies into the mainstream to help address the housing crisis. On Brexit...
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 .
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...
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...