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. We agree that the emphasis is rightly on 'Strong' as well as 'Simple'. We do not subscribe to the view that complex rules are somehow better or more robust. We believe that simple rules that are easy to understand and easy to implement are superior to pages of complex rules that are more prone to misinterpretation or implementation issues. Simple rules work best if coupled with sound risk management and smart supervisory oversight.

You can read the BSA's full response here