The circulation of “bad apples” has to stop and the requirement to provide and to seek regulatory references may achieve this goal.  Building on current regulatory practice is a step in the right direction.  Therefore in principle, the proposals should not be a major long-term burden on building societies but in a few parts they could be.   
 
Our main concerns are the cost and administrative burden on societies, a sector that has consistently demonstrated “good” conduct, and the short timescale to implement these changes.    In the last three years, only 0.2% of all fines levied by the FCA and its predecessor, the FSA, have been on building societies.  Yet they are subject to the same regime.  This may be necessary but it is not proportionate.

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