CML and the Building Societies Association (BSA) have responded to FSA's consultation paper on responsible lending. Both organisations have concerns about many parts of the proposals, including that FSA has not taken account of changes in the market or the effects of prudential requirements and potential new rules on lenders' behaviour. They also think FSA has not carried out a proper cost benefit analysis. CML has also responded to FSA's consultation on arrears charges. It agrees with FSA's suggestions in principle but thinks FSA may be planning to implement change too quickly without assessing the effects of other forthcoming changes.