The British Bankers Association (BBA) has recently published its comments on the PRA CP 33/15and FCA Guidance Consultation 15/5 relating to ring-fencing transfer schemes (RFTS). In summary, the submission states:

  • The BBA strongly believes that the final PRA policy statement and FCA guidance on RFTS needs to contain a common statement that provides a joint commitment from both regulators, to work together with firms to implement ring-fencing in an efficient and orderly manner.
  • Comments encouraging both regulators to develop an industry-wide generic communication to be used by banks to explain ring-fencing to consumers and affected persons.
  • Comments on the process and timing of stages.
  • Clarification requests on the process for assessing scheme reports.