Today the BSA is publishing its responses to three PRA CPs including the proposals on the capital aspects of the new regime for Small Domestic Deposit takers (SDDTs) and the removal of the so-called refined approach to Pillar 2a.

The BSA has been a supporter of the Strong and Simple project since the outset. We believe that simple rules that are easy to understand and straight forward to implement are not weaker and can, in fact, be stronger.

We support the proposals but highlight the subjectivity in the requirements, particularly for operational risk. We call for the PRA to set out principles on how they will make such judgments to give firms more certainty. We also call for the PRA to set up internal governance processes with a clear mandate to assess proportionate implementation of the requirements and hence guard against the risk of gold-plating or ‘supervisory creep.’  

BSA Response to CP7/24 proposals for SDDTs

BSA Response to CP8/24 proposals to move capital requirements into PRA Rulebook

BSA Response to CP9/24 Proposed removal of the refined approach