Industry Responses


The BSA often comments on consultative papers issued by the Financial Services Authority, and by government departments such as the Treasury or the Department of Trade and Industry. Below are the latest BSA responses to recent consultations.


Forbearance and Impairment Provisions FSA Guidance Consultation: Response by the BSA - 15/06/2011 - The BSA response to the FSA Guidance Consultation on Forbearance and Impairment Provisions relating to mortgages.

A Competition Regime for Growth: A Consultation on options for reform - 10/06/2011 - Response by the Building Societies Association

Equality Act 2010: Banning age discrimination in services, public functions and associations - 23/05/2011- A consultation on proposed exceptions to the ban - Response by the Building Societies Association

Response to DP11/1 Product Intervention - 21/04/2011 - The BSA has responded to FSA Discussion Paper 11/1 on product intervention.

The future of financial reporting in the UK and Ireland - 24/04/2011 - An Accounting Standards Board consultation
We argue that the proposed three-tier framework is not a proportionate response. It does not consider the unique position of mutuals.

Our response to EC consultation on additional taxes for the financial sector - 18/04/2011 - Our response to EC consultation on additional taxes for the financial sector. We argue these hit mutuals disproportionately hard.

A New Approach to Financial Regulation: Building a Stronger System - 14/04/2011 - HM Treasury and the Department for Business, Innovation & Skills Response by the Building Societies Association

Our response to FSA guidance consultation on code of practice for the auditor and supervisor, GC 11/05 - 25/03/2011Our response to FSA guidance consultation on code of practice for the auditor and supervisor, GC 11/05. We support the principle but contest some of the detail.

Simple Financial Products - 24/03/2011 Response by the BSA

2011 Budget 16/03/2011 - BSA submission. The BSA Budget Submission has been sent to the Chancellor and can now be viewed on the wesbite.

EU Commission consultation on access to a basic payment account- 17/11/2010 EU Commission's proposals to ensure that no EU citizen or resident is denied access to a basic bank account.

FSA Mortgage Market Review - Responsible Lending Consultation CP10/16- 15/11/2010 Response by the BSA.

FSA Mortgage Market Review - Responsible Lending Consultation CP10/16- 15/11/2010 Response by the BSA.

Children's Savings: Options for a future account- 28/10/2010 A submission by the Building Societies Association.

HM Treasury - A New Approach to Financial Regulation: Judgment, Focus and Stability- 19/10/2010 BSA response.

FSA Mortgage Market Review: Interest Only and Non deposit taking lenders- 08/10/2010 Response by the BSA.

Loss Absorbency of Regulatory Capital- 04/10/2010 A Response by the UK Building Societies Association to the Basel Committee's August 2010 consultative document (CP 174).

Our response to the FSA's DP 10/03 on enhancing the auditor's contribution to prudential regulation- 28/09/2010 We give a cautious but qualified welcome to the proposals.

21st Century Welfare - DWP consultation Response by the BSA- 17/09/2010 The BSA response to the DWP consultation on benefit reform. The response focuses solely on the impact on Support for Mortgage Interest under the Universal Credit proposals.

Response to revised guidelines on common reporting- 16/09/2010 We welcome the aim of the guidelines but have concerns on timing.

Independent Lending Code Review 2010- 13/09/2010 Association's response to the 2010 independent review of the Lending Code.

European Commission Green Paper on corporate governance in financial institutions and remuneration policies- 01/09/2010 A Response by the Building Societies Association.

Lending Code Sponsors' joint response to Chapter 7 of FSA's July 2010 Quarterly CP - Proposed changes to BCOBS- 31/08/2010 The Lending Code sponsors (BSA, BBA and UKCA) have responded to the FSA's proposed changes to BCOBS. The proposed changes relate primarily to the use of the right of set off.

BIS - Call for Evidence- 17/08/2010 Consumer Rights Directive: Allowing Contingent or Ancillary Charges to be Assessed for Unfairness.

Response to chapter 4 of the FSA's quarterly consultation, CP 10/15 - 13/08/2010 Minor changes have been proposed to the liquidity regime. As they correct unintended errors, we have welcomed them.

BSA submission to OFT review of barriers to entry to retail banking- 09/07/2010 BSA Submission

Capital Related Issues Response - 22/06/2010 BSA Submission

June 2010 Emergency Budget - 10/06/2010
BSA Submission

Consumer Complaints (Emerging Risks and Mass Claims) - 08/06/2010
DP 10/1: Financial Ombudsman Service, Financial Services Authority and Office of Fair Trading
BSA response to DP 10/1: Financial Ombudsman Service, Financial Services Authority and Office of Fair Trading - Consumer Complaints (Emerging Risks and Mass Claims)

Our response to QCP 10/10 (no 24), chapter 4, concerning the simplified ILAS regime - 03/06/2010
We welcome the further modification to enable smaller societies to take advantage of the simplified ILAS regime.

Our response to FSA discussion paper on enhancing financial reporting disclosures, DP 09/5 - 30/04/2010
We urge caution. Is now the right time to be changing financial reporting? We also suggest the FSA needs to consider carefully the needs of mutuals.

Mortgage Market Review: Approved Persons Consultation CP 10/2 - 30/04/2010
The BSA response to the FSA Mortgage Market Review Approved Persons Consultation (CP 10/2)

Mortgage Market Review: Arrears Consultation CP10/2 - 30/04/2010
The BSA response to the FSA Mortgage Market Review Arrears Consultation (CP 10/2)

Ministry of Justice Orders for Sale Consultation - 29/04/2010
The BSA response to the MOJ consultation on orders for sale in relation to charging orders.

Responses on CRD 4 and on Basel 164 and 165 - 16/04/2010
Read our responses to the EC consultation on further changes to the capital requirements directive (CRD 4) and to the Basel Committee consultations on strengthening the banking sector and and on an international framework for liquidity risk management respectively.

Our response to the FSA's fees consultation CP 10/05 - 12/04/2010
We welcome the £1,000 minimum fee but argue - again - against the "premium" for building societies.

COMMITTEE OF EUROPEAN BANKING SUPERVISORS. CONSULTATION PAPER CP 33 ON IMPLEMENTATION GUIDELINES REGARDING INSTRUMENTS REFERRED TO IN ARTICLE 57(A) OF THE CAPITAL REQUIREMENTS DIRECTIVE - 31/03/2010
RESPONSE BY THE BUILDING SOCIETIES ASSOCIATION

Our response to a consultation on capital planning buffers, CP 09/30 - 30/03/2010
Our response to the FSA consultation issued late last year.

Treasury Committee inquiry into mortgage arrears and access to mortgage finance: follow up - 29/03/2010
Response by the BSA

Mortgages: Power of Sale & Residential Property Ministry of Justice Consultation - 25/03/2010
The BSA response to the MOJ consultation on power of sale in relation to residential mortgages.

Response to the FSA's consultation on strengthening capital standards, CP 09/29 - 10/03/2010
Our response to the FSA's consultation on strengthening capital standards, CP 09/29. We address three key issues: hybrid capital, large exposures and securitisation.

BSA response to HMRC's consultation, "Modernising powers, deterrents and safeguards: tackling offshore tax evasion" - 03/03/2010

THE FUTURE OF BANKING COMMISSION - 25/02/2010
A response by the Building Societies Association

BIS CONSULTATION ON POST OFFICE BANKING - 24/02/2010
A response by the Building Societies Association

Financial Ombudsman Service: Corporate Plan & 2010/2011 Budget Consultation - 24/02/2010
Response by the Building Societies Association

Mortgage Regulation - A Consultation - 12/02/2010
BSA has responded to the Treasury's consultation on the regulation of buy to let mortgages, second charge loans and protecting customers when mortgage books are sold on.

DP 09/4 - Turner Review Conference Discussion Paper - 02/02/2010
The BSA's response to DP 09/4 - The Turner Review Conference Discussion Paper

The future of UK GAAP - 01/02/2010
We argue that full lFRS is not suitable for those building societies that have not issued PIBS.

FSA Mortgage Market Review DP 09/3 - Response by the BSA - 28/01/2010
The BSA response to the Mortgage Market Review Discussion Paper (DP 09/3)

Response to FSA consultation on fees and levies policy for 2010/11, CP 09/ 26 - 11/01/2010
BSA response to FSA plans to change its policy on fees and levies. On the whole, we welcome them as they appear to reduce fees for the majority of building societies but have reservations over the proposed "premium" for large deposit takers

Response to questions in fees policy consultation relating to MELs formula - 07/12/2009
Our response to questions in fees policy consultation relating to MELs formula

Scottish Government consultation on Repossession of Residential Property: Protection of Tenants - 09/11/2009
Response by the BSA. The BSA responds to the Scottish Government's consultation on the protection of unauthorised tenants

Pre Budget Report - 05/11/2009
BSA submission

Distribution of Retail Investments: Delivering the RDR - 02/11/2009
BSA Response to FSA CP09/18

FSA Consultation Paper 09/21: Transparency as a Regulatory Tool and Publication of Complaints Data - 30/10/2009
Response by the Building Societies Association

Financial assistance to building societies - 30/10/2009

Consultation by HM Treasury: Special Resolution Regime: The Building Societies (Insolvency and Special Administration) Order 2009 and related insolvency rules, and financial assistance to building societies. - 29/10/2009
Response by the Building Societies Association

HM Treasury consultation - Special Resolution Regime: The FSMS (contribution to costs of special resolution regime) Regulations 2009 - 28/10/2009
A Response by The Building Societies Association

CLG consultation on lender repossession of residential property: protection of tenants - 13/10/2009
Response by the BSA

European Commission Investigation - 08/10/2009
State Aid C 14/08 (EX NN 1/08) - Restructuring Aid to Northern Rock

A Review of corporate governance in UK banks and other financial industry entities (The 'Walker Review') - 01/10/2009
A Submission by The Building Societies Association

BSA response to the White Paper - 01/10/2009

Equality Bill: Making it Work - 29/09/2009
Consultation by the Government Equalities Office.

Response to HMRC's consultation on code of practice on taxation for banks - 24/09/2009
BSA argues that the code is not applicable to building societies.

The Way Forward for Scotland's Banking, Building Society & Financial Services Sector - 11/09/2009
Evidence from The Building Societies Association to the Scottish Parliament's Economy, Energy and Tourism Committee

BSA response to FSA Consultation Paper 09/16 - Financial Services Compensation Scheme: Verification of the Single Customer View - 10/09/2009

Response to Commission Consultation to further changes to Capital Requirements Directive - 08/09/2009

BSA response to the FSA's CP 09/17 - 04/09/2009
A specialist sourcebook for building societies: enhanced supervisory guidance on financial and credit risk management

The Government Response to the Rugg Review - 28/08/2009
Response by the BSA

EU Commission Public Consultation on responsible lending and borrowing in the EU - 28/08/2009
Response by the BSA

BSA response to FSA Quarterly consultation 09/20 - Proposed amendments to Banking Conduct of Business Sourcebook (BCOBS) - 17/08/2009
The Association's response to FSA Quarterly consultation paper 09/20

Treasury Select Committee enquiry into mortgage arrears and access to mortgage finance - 03/08/2009
Response by the BSA

Response to the FSA's consultation Strengthening liquidity standards 3: liquidity transitional provisions, CP 09/14 - 30/07/2009

EUROPEAN COMMISSION CONSULTATION DOCUMENT: REVIEW OF DIRECTIVE 94/19/EC ON DEPOSIT GUARANTEE SCHEMES (DGS) - 29/07/2009
A Response by the Building Societies Association

Response to FSA consultation on liquidity reporting - 16/07/2009
Read our response to the FSA's consultation on liquidity reporting. We believe that smaller societies in particular are facing a disproportionate burden.

CP 09/16 - FINANCIAL SERVICES COMPENSATION SCHEME: CHANGES TO DEPOSIT COMPENSATION - 08/07/2009
Memorandum by the Building Societies Association

FSA Discussion Paper "A Regulatory Response to the Global Banking Crisis" (DP 09/2) - 19/06/2009
The BSA has outlined key areas of concern to Lord Turner on his review and on his remarks post-Dunfermline BS.

The Walker Review - 19/06/2009
A Submission by the Building Societies Association

BERR Consultation on Proposals for Implementing the Consumer Credit Directive - 10/06/2009
Response by the Building Societies Association

Financial Services Authority DP 08/5: Consumer Responsibility - 09/06/2009
Response by the Building Societies Association

Proposed amendment to the regulatory valuation of available-for-sale debt securities, chapter 3 of the FSA's quarterly consultation, CP 09/12 - 05/06/2009
We support the FSA's proposed treatment of assets reclassified from available for sale to loans and receivables as currently allowed by the waiver by consent handbook modification.

BSA writes to Turner with comments on his review - 18/05/2009
The BSA has outlined key areas of concern to Lord Turner on his review and on his remarks post-Dunfermline BS.

Industry response to changes to ISAs in the 2009 budget - 15/05/2009
Read the industry response to changes to ISAs in the 2009 budget. Industry prefers one single date for implementation of higher limits.

BSA Budget submission - 20/04/2009
I am writing to urge you to take action to assist savers in your forthcoming Budget, as well as implementing measures to help support the housing market.

FSA consultation on regulatory fees and levies 2009/10, CP 09/7 - 07/04/2009
Read the BSA response on proposed regulatory fees for the coming year.

Building Societies Association's response to FSA Consultation Paper 09/3: 'Financial Services Compensation Scheme Reform' - 06/04/2009
The BSA welcomes the opportunity to comment on the FSA's Consultation Paper, CP09/3 Financial Services Compensation Scheme Reform, which sets out proposals for facilitating faster payment to depositors under the FSCS, for raising consumer awareness about the FSCS, and for widening the eligibility criteria for compensation for deposits.

BSA response to FSA consultation on stress and scenario testing, CP 08/24 - 31/03/2009
Our response on FSA consultation on stress and scenario testing. We question proposals on reverse stress testing and overlap with other requirements.

BSA response to CP 08/23 on financial stability and depositor protection - 06/03/2009
Our response on consumer responsibility and depositor protection.

BSA response to the FSA quarterly consultation no 19, CP 09/02 - 06/03/2009
We respond to a minor point on integrated regulatory reporting in this quarterly consultation paper.

BSA response on fee and levy rates for 2009/10 (CP 09/7) chapter 15, the FSCS management expenses levy limit - 06/03/2009
We express concern at level of management expenses levy limit building societies asked to pay.

Compliance Partnerships: An OFT consultation on developing the use of 'established means' - 05/03/2009
The BSA's response to Compliance Partnerships: An OFT consultation on developing the use of 'established means'

BSA response to the FSA consultation on liquidity requirements - 04/03/2009
We respond to the FSA on its proposed liquidity regime. A major concern is the focus on treasury bills in the standardised regime for "simpler" firms such as the majority of building societies.

FOS Corporate Plan and 2009/10 Budget - 20/02/2009

BSA response to FSA CP 08/19: Regulating Retail Banking Conduct of Business - 16/02/2009
The Association's response to the FSA consultation on the proposed new framework for regulating retail banking conduct of business.

BERR Consultation on EU Proposals for a Consumer Rights Directive - 05/02/2009
The Building Societies Association (BSA) welcomes the opportunity to submit written evidence to the Committee.

BSA response to CLG inquiry on Local Authority Investments - 22/01/2009
Submission by the Building Societies Association to the Communities and Local Government Committee for its inquiry on Local Authority investments.

BSA Response to the Government's Consultation on the Homeowner Mortgage Support Scheme - 14/01/2009
The Building Societies Association (BSA) supports the Government's overall objective of helping support homeowners facing financial difficulties. We welcome the opportunity to comment on current proposals for a new Homeowner Mortgage Support Scheme, as announced by the Prime Minister on 3 December 2008.

Special Resolution Regime: Safeguards for partial property transfers and draft code of practice - 08/01/2009
This paper provides the Association's response to the consultation paper published by the Treasury in November 2008 on safeguards for partial transfers under the Special Resolution Regime (SRR) proposed under the Banking Bill, and the draft Code of Practice for use of the SRR.

BSA Response to FSA CP 08/15: FSCS Review of limits - 07/01/2009
The BSA's response to FSA's proposals on FSCS limits

Response to the FSA's consultation on liquidity requirements, CP 08/22 (chapter 8) - 06/01/2009
BSA's response to the FSA's consultation on liquidity requirements (chapter 8).

Publication of Complaints Data: Next Steps - Discussion Paper by the Financial Ombudsman Service - 06/01/2009
This Paper provides the BSA's response to the discussion paper prepared by the Financial Ombudsman Service (FOS) entitled publication of complain data; next steps.

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