BBA has responded to Treasury's consultation paper on the new approach to financial regulation. It supports Treasury's model, but thinks it has not built in enough checks and balances. Its comments include:

  • the need for further consideration of the democratic accountability of the Bank of England given its increased role;
  • commitment to due process and consultation from the new Prudential Regulation Authority (PRA) and other bodies;
  • potential disadvantages to the Consumer Protection and Markets Authority (CPMA) being vaunted as a consumer champion and the need to consider FSCS and FOS aspects of its creation and the potential transfer to it of consumer credit regulation;
  • the importance of keeping a coherent markets division that can properly represent the UK internationally and exercise enough oversight of market activity. In particular, BBA does not agree that modern infrastructure providers are indistinguishable from large investment firms;
  • noting possible advantages if firms can benefit from the regulators sharing services, such as permissions and approved persons;
  • support for a single financial crime agency but belief that prosecuting insider dealing and market abuse sits better within CPMA;
  • desire for heightened involvement from the Chancellor in a crisis, with a more formal institutional structure for dealing with crises; and
  • support for recruitment of high-quality regulatory staff and secondments of UK staff to the new European Supervisory Authorities.