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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...
Introduction The Building Societies Association represents mutual lenders and deposit takers in the UK including all 46 UK building societies. Mutual lenders and deposit takers have total assets of over £375 billion and, together with their subsidiaries, hold residenti...
Introduction The Building Societies Association is pleased to respond briefly to the EBA’s consultation. The BSA represents all 44 UK building societies. Building societies have total assets of over £330 billion and, together with their subsidiaries, hold residential mo...
Summary The FSA wants to give further information on how it expects firms to evaluate their pension obligation risk and how it assesses this in firms’ ICAAP submissions. This information is additional to the guidance on Pillar 2 pension obligation risk calculations it rece...
Background The Building Societies Association is pleased to comment on the PRA’s proposals in CP 8/13. We represent mutual lenders and deposit takers in the UK including all 45 UK building societies. Mutual lenders and deposit takers have total assets of nearly £380 bil...
We welcome the proportionate and pragmatic approach proposed by the FRC towards incorporating international financial reporting standards into FRS 102. In particular, we support the decision to delay implementation of more significant changes to the standard to allow UK GAAP...
Generally speaking, we agree that the UK Authorities need to have detailed knowledge and understanding of a deposit-taker’s business to exercise the Special Resolution Regime tools and enable the orderly resolution of a failed firm without relying on taxpayer support. The ...
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...
Response by The Building Societies Association to the HM Treasury Consultation Document Introduction 1. This paper sets out the brief comments of The Building Societies Association on the HM Treasury consultation document The new Capital Adequacy Directive, CAD 3:...
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...
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...