BBA has responded to the Walker Review consultation. It strongly supports the paper's proposals, but notes any changes that increase board oversight of pay and bonuses must be harmonised with FSA and Government initiatives. Its other major comment is on the scope of changes and it wants more analysis on whether new requirements should cover UK subsidiaries of foreign banks and smaller and non-listed banks. It also says changes should not place demands on NEDs that might confuse their roles with those of executive directors and which they will find it hard to meet in practice.