The BSA highlights four proposals that would help first time buyers to step onto the property ladder and savers to build their financial resilience.

The BSA supports the PRA's approach to securitisation

BSA Response to House of Lords Inquiry on UK Regulators

BSA response to FCA CP23/20 and PRA CP23/18

BSA Response to FRC Ethical Standard Revisions

Our response to the FRC's consultation on changes to the UK Corporate Governance Code

Our response to FCA GC23-2

The BSA's Response to CP 11/23 "PRA's Statement on the Review of Rules"

BSA Response to HMT Consultation

BSA Response to the 2024/25 FCA Fees and Levies consultation. 

BSA response to LUHC Committee shared ownership inquiry

The BSA's response to the Bank of England consultation paper on solvent exit. 

The BSA has written to the Chancellor ahead of his Budget on 6 March.

The BSA response to Bank of England CP9/23. The Bank has now published PS1/24 providing feedback to CP9/23 and also contains the Bank's final policy.

We see no benefit for building societies in these PRA-driven proposals. 

The BSA supports the proposals in CP6/23 to remove the capital deduction for non-performing exposures.

The BSA has responded to the consultation which examines the currently system of Recognised Professional Bodies (RPBs) regulating insolvency practitioners.    

Increasing capacity and competition in the audit marketplace is a very important topic for our members.

The BSA responded to the Financial Conduct Authority's Credit Information Market Study Interim Report, which can be found here. 

The BSA publishes its response to CP16/22 – the PRA’s implementation of Basel 3.1

The BSA has submitted its final response to CP23/7.

Summary BSA and UK Finance response to RICS Cladding consultation:  Valuation of properties in multi-storey, multi occupancy residential buildings with cladding  

The BSA is a strong supporter of the 'Strong and Simple' project and welcomes the proposals included in CP4/23, while also believing that the proposals could go further.

The BSA's response to HM Treasury's call for evidence on the Senior Managers & Certification Regime

The BSA has responded to the Prudential Regulation Authority's (PRA) Buy-to-let underwriting standards consultation, which looks to introduce tighter underwriting standards for buy-to-let lending, in ...

The BSA responded to a 2016 Bank of England consultation on proposals for a loan level data collection for buy-to-let. The current threshold level for the buy-to-let data requirements is £20m of new b...

BSA response to PRA CP7/23: Regulated fees and levies: Rates proposals 2023/24

The BSA has responded to the Financial Ombudsman Service's consultation Our 2023/24 plans and budget.

BSA responds to FCA Consultation CP22/23 Fees and levies proposals for 2023/2024

The BSA responds to the PRA's CP7/22 Credit Unions: Changes to the regulatory regime

BSA welcome FCA guidance for firms supporting borrowers impacted by the rising cost of living. We are pleased that the focus remains on forbearance tailored to the individual borrower's needs and circumstances

The BSA has responded to DP4/22 The PRA's approach to policy

Summary of BSA remarks at Financial Services Bill Committee

BSA response to the FRC's consultation on the funding of the new Accounting, Reporting and Governance Authority (ARGA). We argue for a proportionate approach using a 'polluter pays' principle.

The BSA broadly supports the proposals and calls for proportionate implementation and cautions against a maximalist approach. 

BSA response to the Climate Change, Environment, and Infrastructure Committee of the Senedd Cymru.

The BSA welcomes the opportunity to respond on behalf of its members to the FOS’s discussion paper on creating a funding model for the future. It is helpful and encouraging that the FOS is seeking vie...

BSA maintains support for PRA's overall Strong and Simple initiative

BSA welcomes the Bank's engagement with enabling better use of HQLA buffers, and we contribute insights from our members

Our main concerns relate, as ever, to cost control and to the lack of an appropriate fees tariff for building societies.

We submit a brief response highlighting again concerns about cost control.

The BSA's repsonse to the Government consultation

BSA response to the HM Treasury call for evidence

BSA response to CP21/34 - Improving the Appointed Representative regime

The BSA welcomes the Government's proposals to amend the Building Societies Act 1986, and supports the individual measures proposed, many of which derive from the BSA’s own advocacy. We are pleased to...

The BSA responds to the FCA's CP on A New Consumer Duty

BSA responds supportively to Treasury's proposals for reform, and makes suggestions for improvement.

The BSA strongly supports the FCA's proposals.

The costs of funding the Bank of England's policy costs should be widened to include large firms in other FS sectors such as insurers.  We support the introduction of a levy but are concerned that the...

We urge DWP to look again at the proposed reporting requirements for “notifiable events”.  There could be  unintended consequences for building societies (and other regulated financial services busine...

The BSA's Submission ahead of the Autumn Budget

The Finance Bill Sub-Committee has consulted on two areas of the draft Finance Bill 2021-22

The BSA and its members strongly support the steps being taken by the Bank of England, PRA and FCA to engage in a more formal dialogue on diversity and inclusion.

Our response to the BEIS Reforming competition and consumer policy consultation

BSA responds briefly on reviews of wholesale markets and the prospectus regime.

BSA broadly supports Bank's further proposals on MREL

BSA supports reform of Better Regulation Framework along lines of TIGRR report.

The BSA responded to HM Treasury's Access to Cash consultion. 

BSA broadly supports (most of)  the proposals in the two linked CPs.

The BSA has responded to the FCA's Call for Input on Open Finance, which looks to bring Open Banking data standards to a wider range of financial products and services.

Read the BSA's submission to the call for evidence.

We believe that building societies other than the largest should not fall within the definition of a public interest entity.

Our main concerns relate to cost control and to the lack of an appropriate fees tariff for building societies.  

The BSA welcomes the overarching aims and desired outcomes that the measures proposed in CP21/1 set out to achieve.

The BSA's response to the FCA consultation

BSA response to the APPG

BSA welcomed this wide-ranging DP and suggests several  improvements to the Bank's approach.

We question the benefits of quarterly reporting.

BSA  supports Treasury proposals in FRF Review Phase II

The BSA has concerns about the potential side-effects from these proposals and impacts on the housing market.

BSA broadly supports PRA's IRB floors for UK mortgage risk weights but suggests improvements to CP 14/20

One concern is the proposed transaction fee under the senior managers regime.  We believe the FCA should defer further discussion of this proposal until it provides more information and improves the a...

The BSA welcomes to the opportunity to response to the FOS's annual consultation on its plans and budget.  While we remain supportive of its stated strategic priorities, we also remain concerned at th...

The BSA welcomes the opportunity to respond to this consultation on proposed further support for mortgage customers impacted by the coronavirus.

BSA welcomes corrective prudential,action on new and fast-growing banks

We welcome the PRA's move.  But we also argue for a reduction in frequency for the production and review of the recovery plan for those firms eligible for simplified obligations, and for clarity on wh...

Our written evidence to the House of Lords sub-committee on the draft Finance  Bill 2020-2021.

BSA broadly supports PRA proposals but challenges PRA to be more ambitious in cutting compliance burdens

We support proposals set out in the consultation paper to strengthen operational resilience, but we ask for further clarification and guidance on some specific areas.

We support proposals set out in the consultation paper to strengthen operational resilience, but we ask for further clarification and guidance on some specific areas.

We urge the PRA to review all its deadlines, particularly the one for the review of legacy outsourcing agreements, which we believe should be extended until at least 2023.   This is especially importa...

BSA supports continued CRD exemption for credit unions

BSA challenges potential freezing of customer deposits under BRRD 2 moratorium power

BSA challenged unfair PRA offsetting proposals

BSA response to energy efficiency inquiry

In GC20/2, FCA sets out planned guidance for banks, building societies and credit unions to follow when planning closures of branches or ATMs or converting ATMs from free to customer to fee-charging.

The BSA response to the Government consultation paper on expanding the dormant assets scheme.

BSA responds to the MHCLG consultation on design and delivery of the First Homes scheme.

Our main concerns with these proposals, and the fees and levies policies in general, relate to cost control and to the lack of an appropriate fees tariff for building societies.  Many points are mirro...

Our main concerns relate to cost control and to the lack of an appropriate fees tariff for building societies.

BSA broadly supports FCA measures

We set out our concerns about the draft code's potential impact on maturity communications and urge the ICO to liaise with the FCA.

Our comments are brief and high level and reflect our concerns about the rising costs of operating the FSCS.

The BSA sets out its concerns regarding the FCA's proposed amendments to the guidance on the definition of a "Payment Account".

We call for more systematic proportionality to reduce the unnecesssary burdens on small, non-complex banks, including most building societies.

The main proposals are reasonable, and will improve clarity and transparency.

We broadly welcome and support the review proposals

BSA calls for parity for mutuals, "think small first", and some legislative updating.

The BSA response to the MHCLG Discussion Paper on shared ownership.

The BSA has responded to Labour's proposals for leaseholders.

Large building societies have confirmed they are able to report the PRA 110 on a daily basis in times of specific or market liquidity stress – but warn there could also be resource implications to suc...

We support HMRC's move to ensure that maturing CTFs do not lose their tax advantaged status post-maturity.  BSA and its members contributed to the response facilitated by industry group, TISA.

New funding proposals from the Financial Ombudsman Service run counter to the principle of 'polluter pays' with more cost falling on those firms with fewer complaints.  The BSA has responded to the om...

BSA response to the FCA discussion paper on intergenerational differences between Baby Boomers, Gen X and millennials, and their differing financial outcomes.

BSA response to an MHCLG consultation proposing a new regulatory framework for building safety.

The BSA welcomes this consultation on current advice and selling standards.  The aim of these proposals is to provide greater consumer choice and allow the development of further digital solutions. 

The BSA has responded to FCA proposals to help Mortgage Prisoners by enabling lenders to utilise a modified affordability assessment.

In light of the series of recent accounting failures at large UK companies a review of the current regulatory arrangements is clearly overdue.  We welcome this move.   This is an opportunity to promot...

We argue for a more appropriate fees policy for mutuals.   Treating building societies the same as banks ignores the differences in risk and business models.

BSA response to the FCA/PRA's to the FCA/PRA's consultation on changes to mortgage reporting requirements. We made the following recommendations. * Expand the data fields in PSD007 to better capture ...

Our response focuses on HQLA and PRA 110, specifically timing and superequivalence aspects.

BSA response to the Affordable Housing Commission

BSA response to the Housing, Communities and Local Government Committee's inquiry into Modern Methods of Construction. 

BSA response to Law Commission consultation on reinvigorating commonhold.

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...

The BSA has submitted comments on the FCA's Discussion Paper 18/9 "Fair Pricing in Financial Services", which sets out a framework for assessing the fairness of price discrimination practices.

These proposals present significant complexities to mortgage lenders and would mean significant disruption to existing systems and processes which work well for the benefit of customers.

The BSA is pleased to respond to the consultation by the Financial Ombudsman Service on its strategic plans and budget for 2019/2020

The BSA welcome the Law Commission’s proposals which support governments recent work to simplify and make the leasehold process more fair for leaseholders.  The paper looks at simplifying the enfranch...

BSA response to the Treasury Select Committee Inquiry

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.    

An overall observation is that, in a competitive market, prices and charges will inevitably vary from product-to-product and firm-to-firm. There is a limit to how far regulators or government should i...

We are urging the FCA to adopt a more targeted and proportional approach, focused on those consumers which it identifies as suffering substantial detriment and the firms which are responsible for that.

The clear conclusion is that, since there are ample rules, law and duties to protect UK financial service customers, there is no need for an additional duty of care.  Therefore, we do not support the proposal.

We agree with the spirit of the consultation which addresses a potential gap in protection for consumers choosing to apply for home finance via a Peer to Peer (P2P) platform. 

The BSA's response to FCA CP 18/19

Order introducing senior non-preferred debt for MREL purposes. BSA supports the SI's approach.

We point out the lack of independent oversight and lack of appeal for taxpayers.  We also question the timing and process of the proposals.

The BSA response to the FCA guidance consultation

We endorse the FCA’s underlying objectives for the CMC industry to be well regulated and properly focused on the fair treatment of customers.  We believe that, despite significant resource constraints...

The BSA response to the FCA Consultation

The BSA responded briefly to PRA's CP 6/18 on this subject.

BSA submits response to Commission's brief exploratory consultation, and argues strongly for greater proportionality.

The BSA responds to the FCA consultation

We argue the pool of contributors should be widened beyond deposit takers.

It is clear from the original BBSI proposals, the revised versions, and from follow-up meetings with officials that the MTD plans are vague and aspirational with little consideration of the practical ...

The BSA's response to the FCA's consultation.

We argue for the "polluter pays" principle to be applied to the methodology for collecting the Money Advice Service debt advice levy.

We suggest other beneficiaries of the Bank of England's unremunerated policy work are called upon to fund it.  

The BSA's response to the DCLG's Call for Evidence on improving the home buying and selling process.

To be of interest and benefit to the maximum number of building societies (and probably banks), we believe firms should be allowed to deposit client money in unbreakable deposits of up to 95 days.  

The BSA's response to FCA CP17/25.

The BSA's response to PRA CP 12/17

The BSA's response to PRA CP 13/17

A BSA submission to the Commission's work on supporting mutuals.

These requirements appear to go above and beyond the Bank Recovery and Resolution directive.  We are particularly concerned by the "playbook" and "fire drills".

The BSA responded to ESMA's consultation on the implementation of the trading obligation under MiFIR.

We welcome any effort to improve, clarify and simplify accounting regulation.

We welcome the falls in some of the proposed fee rates.  But we note with some disappointment the general increase in the regulator's costs.

An industry scorecard for the regulated financial services sector is a good start but we have some concerns about its applicability to a typical building society.   There are also question marks over ...

The BSA response, which highlights points of differentiation between our sector and PLCs and stresses the extent to which societies are already embracing high standards of corporate governance.

BSA response to the Government's 2017 Housing White Paper, Fixing the Broken Housing Market.

Earliest possible start date is April 2018 ie the start of the tax year.

We argue for a delay in implementation and reduced frequency.

This BSA paper responds to the FCA's consultation, Our Future Mission.

The BSA supports the PRA's proposals regarding the duty of responsibility and the application of the conduct rules to notified/standard NEDs, which are consistent with earlier representations made by the BSA.

This paper responds to FCA Discussion Paper 16/4 (the DP).

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 Englan...

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 ...

BSA response to 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 suspect...

In addition to concerns raised about the impact the scheme could have on other forms of affordable housing, our main point was around how the Starter Homes scheme's 20% discount should be operated. 

The BSA response to the BIS call for evidence.

This requirement could be a burden in some instances for societies.

Knowing that changes to the standard will be carried out only within a triennial review brings certainty to our sector.  Building societies can plan with the assurance that FRS 102 is constant, and no...

We question the relevance of/ added value derived from all but the largest building societies’ data to the Bank of England’s stated objectives in this exercise.

While the second consultation represents a considerable improvement on the first, there remain areas of concern.  There is a long way still to go before Basel arrives at a satisfactory framework to re...

We question why such a monumental change is required at all for building societies when HMT/ HMRC designed the personal savings allowance to take out 95% of taxpayers of savings tax irrespective of fu...

The BSA's submission to the National Infrastructure Commission's call for evidence, focusing on the importance of investment in supporting infrastructure to overcome objections to new housebuilding de...

We argue for changes.  The application of MRELs through the partial transfer strategy to medium sized deposit-takers which have entered the current account market risks creating, through a massive cli...

 In the BSA's response (marked confidential), we pointed out that regulation remained the biggest barrier for our members and while technology could potentially lessen this load in the future, in the ...

BSA response to HM Treasury's consultation

We welcome the slight reduction in the budget but argue for more detail on "strategic change" expenditure.

We support the proposals.

We urge the PPF to amend its rules on the mortgage age variable for this triennium.  Its rigid reliance on Companies House data disadvantages mutuals and other non-corporates.

Our conclusion was that the revised Sourcebook as proposed in CP 12/16 is, overall, if sensibly and flexibly applied, a reasonable vehicle to achieve the PRA’s objectives on risk management, alignment...

The BSA has responded to the Department for Innovation and Skills call for evidenced on improving the consumer landscape and quicker switching.

The BSA has responded briefly to the BCBS CP on reducing variation in credit risk- weighted assets by constraining the use of internal model approaches. We also strongly support the preliminary input ...

We argue that more consideration should be given to use of the accounting valuation to determine societies' own internal assessment of Pillar II pension obligation risk.

We support the paper's aims but argue against LTV and LTI ratios as they do not take individual circumstances into account.

We argue for a delay in implementation and a more proportionate application.

We argue for a later go-live date and a higher level for reporting exposures.

Read our response which addresses very minor changes to the liquidity regime

On the whole, we welcome the revised draft. Our concerns remain, however, on the applicability of the proposals for EIR, impairment and financial instruments for smaller financial mutuals such as bui...

We continue to argue for wholesale exclusion from FATCA provisions for financial mutuals such as building societies. But we also suggest ways to make the current regulations more workable.

Our response to EC consultation on additional taxes for the financial sector. We argue these hit mutuals disproportionately hard.

The BSA welcomes the opportunity to respond to the FOS’s annual consultation on its plans and budget. While we remain supportive of its stated strategic priorities and the need to invest in a change p...

The BSA has responded to the FCA's consultation paper outlining a proposed new Consumer Duty

We agree there should be no order in which firms use the BoE's liquidity facilities or draw down their own liquid asset buffers to meet a liquidity need.

BSA response to the Ministry's of Housing's call for proposals on private shared ownership.

The BSA argues that the Government's targets for energy efficiency will be challenging but possible with a clear timetable. Any support packages for homeowners should be informed by learning from the ...

The BSA welcomes the PRA's focus on climate change but argue that data on losses emanating from climate change in the mortgage book is required before firms can build models and carry out stress-testi...

The BSA has responded to HMT's consultation on public financial guidance. The proposals concern the restructuring of the existing delivery model to create a new pensions guidance body and a new money ...

The Building Societies Association's submission to the House of Lords Economic Affairs Finance Bill Sub-Committee.

See our response to the European Commission Green Paper on Retail Financial Services.

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

The BSA has responded to the FCA Discussion Paper on an Ageing Population and Financial Services. We also contributed a chapter to the Discussion Paper.

The BSA has responded to the House of Lords Economic Select Committee's Inquiry into the UK Housing Market.

We support the representations made by our European partner, the European Association of Co-operative Banks.  Our main concerns lie in proportionality, frequency and the calculation methodology.

The BSA responded to the CLG Select Committee, highlighting our work on lending into retirement and desire to work with develops to increase the supply of suitable housing for older people.

The BSA's response to the Bank of England Bill Committee.

The BSA has formally endorsed the new Code, and we have encouraged all relevant members - i.e. who are UK Market Participants as defined in the Code - to work towards committing to, and embedding, the...

We are disappointed that the “inconsistencies” between the templates in the policy statement and the XBRL taxonomy were not discovered at the time of publication.

We express concern at the implicit assumption that real costs always have to rise. 

Information on the reclaim mechanism for employers in the devolved nations sought.

We argue for more detail on IT spend.

We urge the PRA to use Brexit as an opportunity to review its regulatory reporting requirements, particularly for non-systemic institutions.   FINREP through the back door is not the answer.

The BSA responded to the Law Commission's proposals for updating the Land Registration Act 2002, opposing proposed changes to the ability of lenders to access the indemnity scheme.

The BSA submission ahead of the Autumn Statement

We have set out a number of concerns with the proposal to have a private profit-maximising body operating the Land Registry, as this could lead to disruptions in the registration process and affect th...

More detail needed on how regulations will work in practice.