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Responses to CP
BBA responses to consultation papers are listed below. The most recent are listed in date order. Older responses can be found under the relevant year, alternatively use the search facility.
Please note that this is not all responses released by the BBA, contact us if you are unable to find the response you are looking for at info@bba.org.uk.
| 2008 | | | 2007 | | | 2006 |
BBA and AFME response to CEBS CP39
26/07/2010Draft guidelines for the joint asessment of the elements covered by the supervisory review and evaluation process and the joint decision regarding the capital adequacy of cross boarder groups.
BBA response to CEBS CP35 (revised) on the management of operational risk in market-related activities
26/07/2010The BBA is pleased to respond to the revised consultation.
Joint response to the European Commission's consultation on derivatives and market infrastructure
19/07/2010ISDA, AFME, and the BBA are pleased to respond to the European Commission's "Public consultation on Derivatives and Market Infrastructures".
Response to FSA CP10/9: Enhancing the Client Assets Sourcebook
01/07/2010The aim of achieving greater clarity in contractual agreements should be pursued through market led/industry initiatives.
Financial Instruments: Amortised Cost and Impairment
01/07/2010The British Bankers' Association welcomes the opportunity to provide comments on the IASB exposure draft 'Financial Instruments: Amortised Cost and Impairment'.
BBA response to European Commission on double tax conventions and the internal market
18/06/2010The ICTLG welcomes the European Commission's consultation exercise on double tax conventions.
BBA responds to CEBS CP36: Guidelines on Liquidity Cost Benefit Allocation
10/06/2010The BBA welcomed the development of guidance on liquidity cost benefit allocation.
MiFID Review - Non-Equity Markets Transparency Consultation
04/06/2010Joint BBA final response to CESR's consultation on its Technical Advice to the European Commission in the Context of the MiFID review - Non-Equity Markets Transparency(CESR/10- 510)
Joint response to CESR: MiFID Review - Equity Markets
01/06/2010The Association for Financial Markets in Europe and the British Bankers' Association welcome the opportunity to respond to this paper and look forward to further active engagement in the ongoing debate concerning the European Equity Markets.
MiFID - Intermediaries and Investor Protection Consultation
28/05/2010Joint BBA final response to CESR's consultation on its Technical Advice to the European Commission in the Context of the MiFID review - Intermediaries and Investor Protection (CESR/10-417)
MiFID - Transaction Reporting Consultation
28/05/2010Joint BBA final response to CESR's consultation on its Technical Advice to the European Commission in the Context of the MiFID review - Transaction Reporting (CESR/10-292)
Joint response to CEBS CP38
11/05/2010CEBS' implementation guidelines on Article 106(2)(c) and (d) of Directive 2006/48/EC (CP38)
Joint trade associations' response to Bank of England consultation
04/05/2010Joint trade associations' response to Bank of England consultation on extending collateral eligibility in the Discount Window Facility and transparency for ABS
Joint trade associations' response to the Basel Committee on Banking Supervision
20/04/2010Consultative proposals to strengthen global capital and liquidity regulations, BCBS 164 and 165 issued on 17 December 2009
Response to the European Commission on CRD IV
20/04/2010Commission Services Staff Working Document Possible further changes to the Capital Requirements Directive - February 2010
BBA respond to the CESR consultation on 'Guidance to Report Transactions in OTC Derivative Instruments' (CESR/09-768)
15/04/2010The British Bankers' Association welcomes the opportunity to response to the CESR consultation on 'Guidance to Report Transactions in OTC Derivative Instruments' (CESR/09-768)
BBA response to Basel_CP re the impact of insurance in operational risk modelling
01/04/2010We welcome the guidance offered to supervisors with regard to concentration risk and assessment processes, including the possibility of self-assessment for compliance with the regulatory criteria for recognising insurance mitigation, and to banks for their risk management.
Joint response CEBS CP32 Stress Testing
01/04/2010CEBS' proposed guidance incorporates many elements that we support and we found the high level principles useful.
BBA response to CEBS CP35 re draft guidance on operational risk
01/04/2010The British Bankers' Association is pleased to respond to the consultation on the draft updated guidance on the management of operational risk in market-related activities.
Joint response to CEBS on implementing guidelines regarding instruments referred to in Article 57 (a) of directive 2006/48/EC recast (CP 33)
01/04/2010
Joint response to FSA CP 09/30 on Capital Planning Buffers
01/04/2010We have a number of key concerns that we urge the FSA to address prior to implementation of the proposals set out in CP09/30.
Joint response to CEBS Guidelines on the management of concentration risk under the supervisory review process (CP31)
01/04/2010The Association for Financial Markets in Europe, the British Bankers' Association and the International Swaps and Derivatives Association are pleased to respond to the consultation on the draft updated guidance on concentration risk.
BBA responds to new guidelines for colleges
29/03/2010The BBA has written to the Committee of European Banking Supervisors ('CEBS') welcoming the publication of draft guidelines for the operation of colleges of supervisors.
Banks determined to repay Exchequer in full
18/03/2010Banks are committed to repaying taxpayers in full for their support during the financial crisis, the British Bankers Association said today.
BBA responds to FSA CP09/29: Strengthening Capital Standards 3
10/03/2010The BBA, along with other UK based financial services trade associations, has responded to the FSA's proposals on implementing CRD2 and 3 amendments.
BBA responds to Chapter 3 in FSA CP10/10: Quarterly Consultation
06/03/2010The BBA has responded to the FSA on the review of Integrated Regulatory Reporting guidance.
BBA response to Which? Future of Banking Commission
05/03/2010In this submission the BBA addressed the issues raised by the Commission and also to relate the progress being made on the regulatory reform programme currently being pursued in response to the global financial crisis.
BBA response to Commission on EU cross-border crisis management framework
01/03/2010The BBA is a key contributor to the development of EU financial services legislation and other initiatives.
BBA response to HMT on non-bank lending
24/02/2010The BBA welcomes the opportunity to respond to the HMT discussion paper on 'non-bank lending' and commends HMT's efforts to expand the sources of capital available to UK-based borrowers.
Response to the Turner review conference discussion paper
05/02/2010A full impact assessment on the cumulative effect of regulatory changes on banks should be integral to all proposed industry reforms, the British Bankers Association said today.
Joint ISDA, BBA and AFME response to House of Lords' Call for Evidence on derivatives markets
02/02/2010
BBA respond to the CESR consultation, 'Inducements: Good and Poor Practices'
23/12/2009The British Bankers' Association welcomes the opportunity to response to the CESR consultation, 'Inducements: Good and Poor Practices (CESR / 09-958).
Payroll Tax
23/12/2009"We are finding it impossible to understand from the point of view of senior domestic and overseas executives why the government is proposing to tax now pay that's based on future performance that might not even materialise."
Review of the Money Laundering Regulations 2007
18/12/2009
BBA response to understanding the definition of advice under MiFID (CESR/09-665)
15/12/2009
Risk, reward and responsibility: possible systemic risk levy
11/12/2009The Treasury paper published today raises the possibility of a systemic risk levy.
Industry response to EU Commission Services Staff Working Document
17/11/2009The International Swaps and Derivatives Association (ISDA), the London Investment Banking Association (LIBA), the European Banking Federation (EBF), and the European Securitisation Forum (ESF), an affiliate of the Securities Industry and Financial Markets Association (SIFMA), are pleased to provide industry feedback on the "Commission Services Staff Working Document" on proposed amendments to the Capital Requirements Directive.
Response to CESR consultation on Trade Repositories
10/11/2009This comment paper responds to the Committee of European Securities Regulators Consultation Consultation Paper (CESR/09-837) on Trade Repositories in the European Union, dated September 29, 2009 (the CP).
AIFM Directive: Custody Issues
09/11/2009Article 17
BBA responds to CEBS CP28 on Liquidity Buffers and Survival Periods
03/11/2009The BBA, along with other UK based financial services trade associations, has responded to the CEBS proposed guidelines on Liquidity Buffers and Survival Periods.
BBA Response to FSA CP 09/18
29/10/2009Distribution of Retail Investments Delivering the RDR
BBA responds to the Financial Services Skills Council's consultation on new core standards for retail investment advice appropriate examinations
29/10/2009The BBA response recommends amendments to the proposed new core draft standards
BBA responds to HMT Consultation on Special Resolution Regime (SRR) - contribution to the cost of the SRR regime
29/10/2009
BBA Code for Financial Reporting Disclosure
26/10/2009The UK's seven largest lending institutions have today committed themselves to support a new BBA Code for Financial Reporting Disclosure
BBA Response to FSA CP_09-19 Enforcement Penalties
21/10/2009Our members are the strongest partners of competent authorities in tackling market abuse.
Joint response to CESR CP (CESR/09-618)
02/10/2009The BBA responds to CESR's consultation on the 'clarification and identification of OTC derivatives for the purpose of the exchange of transaction reports amongst CESR Members (CESR/09-618)'.
BBA response to CESR Proposal for a Pan-European Short Selling Disclosure Regime
02/10/2009
Government White Paper 'Reforming financial markets'
29/09/2009In July the Treasury published a White Paper 'Reforming financial markets' in which it set out a further analysis of the causes of the financial crisis and provides an account of the Government's response.
Walker Review of corporate governance
29/09/2009The BBA has today responded to the review conducted by Sir David Walker of corporate governance in UK banks and other financial institutions.
Response to CEBS CP 27 on Implementation Guidelines regarding Hybrid Capital Instruments
24/09/2009The British Bankers Association (BBA) and The London Investment Banking Association (LIBA)are pleased to respond to the CEBS Consultation Paper 27 on its proposed implementation guidelines for hybrid Tier 1 capital instruments and fully support CEBS' objectives of promoting a harmonised approach to the treatment of hybrid instruments by European supervisors.
BBA responds to IASB proposal to reform IAS 39
17/09/2009We have responded to the first part of the IASB's project to replace IAS 39 concerning the recognition and measurement of financial instruments.
BBA response to CP09/16 on SCV verification
09/09/2009FSCS: Verification of the single customer view and changes to deposit compensation
BBA response to CRD4
04/09/2009A response to the EU Commission's Services Working Document on Possible Further Changes to the Capital Requirements Directive
BBA responds to IASB request for information on impairment and own credit risk
03/09/2009The BBA has responded to two requests for information issued by the IASB as part of its project to replace IAS 39.
BBA responds to FSA CP on Strengthening Liquidity Standards 3: Liquidity Transitional Measures (CP09/14)
31/07/2009The BBA, along with other UK based financial services trade associations, has responded to the FSA's proposals "Strengthen Liquidity Standards 3: Liquidity Transitional Measures" (CP09/14).
CESR Consultation on MiFID Complex and Non-Complex Financial Instruments - REF: CESR/09-295
31/07/2009A joint response by APCIMS, LIBA and BBA.
The representative organisations that are signatory to this document welcome the opportunity to respond to CESR's Consultation Paper CESR/209-295 on MiFID complex and non-complex financial instruments for the purposes of the Directive's appropriateness requirements.
BBA responds to European Commission Consultation on the review of the Deposit Guarantee Schemes Directive
27/07/2009The BBA has responded to the European Commission Consultation on the review of the Deposit Guarantee Schemes Directive.
BBA responds to CEBS CP on High-Level Principles for Risk Management (CP24)
20/07/2009The BBA, along with other UK based financial services trade associations, has responded to the CEBS CP on "High-Level Principles for Risk Management" (CP24)
BBA responds to FSA CP on Strengthening Liquidity Standards 2: Liquidity Reporting (CP09/13)
20/07/2009The BBA, along with other UK based financial services trade associations, has responded to the FSA's proposals "Strengthen Liquidity Standards 2: Liquidity Reporting" (CP09/13).
BBA response to FSA CP09/10 Draft code of practice on remuneration policies
01/07/2009The BBA welcomes the opportunity to respond to the FSA's consultation on the draft code of practice on remuneration policies.
BBA response to FSA DP 08/5 Consumer Responsibility
24/06/2009The BBA welcomes the opportunity to respond to DP08/5 on Consumer Responsibility. We trust that the discussion paper will act as the catalyst which properly re-opens the debate on consumer responsibility which stalled somewhat following the FSA’s previous attempts to reach a constructive consensus between industry and consumer representatives on this subject.
Response to OFT's Consultation on their Financial Services Strategy
22/06/2009We welcome the opportunity to provide our comments on the proposals and questions set out in the Financial Services Strategy consultation document and thank the OFT for their open and consultative approach in devising their forthcoming Financial Services Plan.
BIS Consultation: Proposals for implementing the consumer credit directive
16/06/2009BBA has responded to the consultation offering support for the government's concern to promote responsible lending and borrowing, while expressing strong concern about the potential damage that could be suffered through the adoption of too prescriptive an approach to providing "adequate explanations" and assessing "creditworthiness".
BBA Response to FSA CP09 15 Short Selling
15/06/2009Our members welcome FSA's early clarification regarding the temporary short selling regime. We support FSA's proposal to extend the UK short selling regime in its current format.
BBA's response to FSA Discussion Paper 09/2
15/06/2009A regulatory response to global banking crisis.
Banks stress need for international cooperation on reform
15/06/2009Proposed reform of UK banking regulation needs more work and must take account of how British financial services interact with global markets the British Bankers’ Association [BBA] said today.
Harmonisation of Securities Law consultation
12/06/2009The BBA has responded to the European Commission's Harmonisation of Securities Law consultation.
BBA response to Commission's Call for Evidence on MAD
11/06/2009The BBA (British Bankers Association) and ICMA (International Capital Markets Association) are pleased to respond to the European Commission's Call for Evidence on the Review of Directive 2003/6/EC on insider dealing and market manipulation (the Market Abuse Directive).
BBA Response to FSA DP09/01 Short Selling
11/05/2009We support the four principles outlined in the recent IOSCO report on short selling.
Joint trade associations' response to BCBS CP 150
28/04/2009Proposed enhancements to the Basel II framework - Pillar 1
Commission Consultation on Financial Market Supervision
09/04/2009The BBA agrees that there are a number of significant changes that need to be taken both in Europe and internationally to provide high quality macroeconomic analysis; to build structures to improve financial stability; to revise regulatory frameworks; to address gaps in regulation; and to improve cooperation and coordination amongst supervisors. Although many of these issues need to be addressed on an international basis, or in coordination with authorities around the world, the BBA recognises the need to bring about a coherent solution for the EU.
FSA CP08/25: The Approved Persons Regime
08/04/2009The BBA welcomes the opportunity to respond to FSA CP 08/25: The Approved Persons Regime - significant influence function review. Click here for the full response.
BBA Response to FSA CP 09/3 - Financial Services Compensation Scheme reform
07/04/2009The BBA welcomes the opportunity to respond to CP 09/3.
Recent market turmoil and resulting bank failures has highlighted the need for enhancements to Deposit Guarantee Schemes (DGS) across Europe.
Financial Crisis Advisory Group
02/04/2009The BBA has responded to a request for input from the joint IASB/FASB Financial Crisis Advisory Group.
Joint Trade Association Response to FSA CP 08/24
31/03/2009The joint associations (BBA, ISDA and LIBA) welcome the opportunity to comment on the FSA's consultation paper entitled "Stress and scenario testing" (CP08/24).
Joint Trade Association Response to BCBS 148 and 149
16/03/2009The International Swaps and Derivatives Association (ISDA), the Institute of International Finance (IIF), the London Investment Banking Association (LIBA), and the International Banking Federation (IBFed), are pleased to provide additional feedback on the Basel Committee on Banking Supervision's (BCBS) consultative documents "Proposed Revisions to the Market Risk Framework" and the "Guidelines for Computing Capital for Incremental Risk in the Trading Book".
Joint Trade Association Response to BCBS Stress Testing Consultation
16/03/2009Principles for sound stress testing practices and supervision - a joint response by the trade associations
The International Banking Federation (IBFed), the International Swaps and Derivatives Association (ISDA) and the London Investment Banking Association (LIBA) are pleased to feedback on the Basel Committee on Banking Supervision's Principles for sound stress testing practices and supervision - CP147.
Joint Trade Association response to FSA CP on Strengthening Liquidity Standards (CP08/22)
06/03/2009The BBA, along with other UK based financial services trade associations, has responded to the FSA's proposals "Strengthen Liquidity Standards" (CP08/22).
BBA respond to CESR on the call for evidence (CESR/09-074).
03/03/2009Call for evidence on the technical standards to identify and classify OTC derivative instruments for TREM; CESR's transaction reporting exchange mechanism (CESR/09-074)
Joint Repsonse to FSA on obtaining and using firm-commissioned reports
03/03/2009The BBA and LIBA welcome the opportunity to respond to FSA's consultation paper CP 09/05 on the use of firm commissioned reports.
BBA Response to European Commission CP on Hedge Funds
01/02/2009Sound markets practices increase investor confidence, promote market efficiency and enhance the competitiveness of banking and finance.
BBA Repsonse to BERR Implementation of Shareholder Rights Directive comsultation
30/01/2009
Response to Rights issue subscription periods
26/01/2009The BBA is in favour of reducing the length of rights issue acceptance periods to at least 14 calendar days or 10 business days and support the consequent amendments that need to be made to the Listing Rules to allow this.
BBA response to CESR/ESCB Consultation Paper: Draft Recommendations for Securities Settlement Systems and Draft Recommendations for Central Counterparties
21/01/2009We have focussed in this response on the operational risk elements, but would also point out that we endorse the comments provided by the European Banking Federation in regards to the rest of the proposed recommendations
FSA Regulatory fees and levies: policy proposals for 2009/10
19/01/2009The BBA welcomes the opportunity to respond to the above named consultation.
Industry response to the Dec 08 CESR consultation on Post-Trade Transparency
16/01/2009
Final response to CESR's call for evidence on MIFID impact on secondary markets
13/01/2009CESR call for evidence on impact of MIFID on equity secondary markets functioning
BBA / ICMA joint response to CESR consultation CESR/08-717
13/01/2009The British Bankers' Association (BBA) the International Capital Market Association (ICMA) are pleased to respond to the above consultation.
BBA Response to FSA CP09/01 Short Selling
12/01/2009
Joint Trade Association preliminary response to Chapter 8 FSA CP08/22
09/01/2009The Joint Trade Associations (JTA) broadly welcome the proposed FSA proposals outlined in its Consultation Paper (CP) 08/22 "Strengthening Liquidity Standards."
Financial Services Compensation Scheme: Review of Limits
08/01/2009BBA Response to FSA CP 08/15
UK Market Implementation Group's response to the Corporate Actions Joint Working Group consultation
07/01/2009on Market Standards for Corporate Actions Processing.
FSA Regulatory fees and levies: policy proposals for 2009/10, Chapter 10
06/01/2009The BBA welcomes the opportunity to respond to the above named consultation.