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Our question to the EBA on the scope of FINREP Topic : Supervisory reporting Legal act : Capital Requirements Regulation Legal reference : Article 99, paragraphs 2 - 4 Subject matter : Scope of application of FINREP Our question concerns paragraph 4. Does it empo...
An overwhelming concern with the draft technical standards is the timing. Radically new reporting requirements, as COREP and FINREP templates are, require systems alterations and testing, both of which usually take a minimum of 12 months. Our larger members tend to be th...
Summary We support efforts to introduce global standards of liquidity for deposit takers and appreciate the need of regulators for accurate, comparable, relevant and timely information to enable them to supervise and monitor risks. Like our members, we are keen to e...
Summary We support efforts to introduce global standards of leverage for deposit takers and appreciate the need of regulators for accurate, comparable, relevant and timely information to enable them to supervise and monitor risks. Like our members, we are keen to en...
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...
Note to EBA Our position is somewhat different to the rest of Europe since the UK has voted to leave the European Union. The actual departure date is unknown, and until that point all aspects of the EU Banking Single Rule Book - CRR, delegated acts, RTS, guidelines etc - wil...
Executive summary We wish to record our thanks to the PRA team who took the time and trouble to discuss their plans with a group of societies on 10 June 2016. At the time, the referendum on UK membership of the EU had not yet happened so “Brexit” was not considered. But B...
We find no case for mandatory replacement of FSA 015 at this early stage. Time is needed for IFRS 9 to bed in before any change is made to reporting. What may look important now may not be once the full impact of the new standard has been felt. 2021 could be a more appropr...
The proposed six-month extension of existing returns FSA 047 and FSA 048 is driven by problems with PRA 110. We therefore urge the PRA to delay implementation of this new return. A delay will give the regulator time to consider if data provided by other liquidity returns, s...
We propose that by removing the requirement to provide the child’s address on the CTF annual statement, the safeguarding risk that could arise from it would be eliminated. Implementing system changes and process controls mitigates the risk but does not eliminate it completel...
We are pleased to have the opportunity to provide feedback on this occasional consultation paper. We have no comment on the detail of the minor changes proposed. But we are disappointed that the “inconsistencies” between the templates in the policy statement and the XBRL ta...