The BSA have today, Monday 8th April 2024, responded to the PRA consultation outlining proposals for the PRA's approach to policy making, CP27/23 which you can find here. 

The Approach to Policy outlines the key principles and procedure the PRA will follow in its review and creation of policy going forward, following on from DP 4/22 in September 2022. 

The Approach to Policy makes some amendments from the previous iteration, notably that:

• The PRA will take a proactive approach to the secondary competition and growth objective
• International standards will largely be implemented flexibly in line with the needs of the UK market
• The PRA will consult on changes to the scrutiny of its Cost Benefit Analysis process
• A broader range of stakeholders will be consulted on rule changes
• The PRA Rulebook is proposed to be reformed to improve accessibility, readability, clarity and efficiency

The BSA have now responded to this consultation, which you can find here. 

In summary the BSA response:

• Welcomes continued commitment by the PRA to proactively delivering on the secondary competition and growth objective
• Raises concerns that recent PRA policy areas have not proactively considered the impact of policy on mutuals
• Welcomes the new mechanisms by which stakeholders can raise concerns or views about existing policy
• Strongly recommends that in the PRA improving the Rulebook readability that it employs a 'one in one out' rule for adding new regulation