Consultation Responses


As the principal trade association for credit unions in Britain and a key player in the development of inclusive financial services, ABCUL actively responds to many consultations and enquiries. Our responses to the following consultations are available to view below.

Latest Responses

HMRC - ISA Compliance and Penalties Call for Evidence

ABCUL responds to HM Revenue & Customs Call for Evidence onf the ISA compliance and penalities regime. Download

FCA - A New Consumer Duty: Further Consultation

ABCUL responds to the second FCA consultation on the New Consumer Duty proposals.  Download

Ministry of Justice - Small Payments Scheme

ABCUL responds to Ministry of Justice proposals for a new payments scheme to allow people to draw out small sums (up to £2,500 over 6 months) on behalf of mentally incapacitated without the often long process of applying to the Court of Protection. Download

HMT - Regulation of Buy-Now Pay-Later (BNPL)

ABCUL responds to the Treasury's consultation on including Buy Now Pay Later in the scope of FCA regulation.  Download

FCA - Debt Packagers: Proposal for new rules

ABCUL responds to the proposals to ban firms from receiving income from referring insolvency solutions. This adds costs whilst adding very little value to the insolvency process and ABCUL strongly supports this as part of wider reform in the insolvency sector. Download

Diversity and inclusion in the financial services sector - working together to drive change

ABCUL submitted a response to both financial regulators who are exploring regulatory interventions to promote diversity and inclusion within the financial services sector. Our response, as ever, argues for proportionality when apply regulations to credit unions. The response asks for the regulatory to take into consideration the gulf in culture between credit unions and other financial firms. One example highlighted was that only 9.7% of other firms had female senior leadership representation compared to 60% in credit unions. Download

Financial Conduct Authority – A New Consumer Duty

ABCUL has responded to Financial Conduct Authority’s consultation on a new consumer duty. The proposed consumer duty would put the onus on firms to ensure good consumer outcomes and may open the door for private litigation for regulatory breaches. Download

ABCUL Responds to FCA Regulatory Fees Consultation

ABCUL has responded to the FCA's fee consultation. The key proposal that ABCUL has responded to was the introduction of a new £250 application fee for Senior Management Functions (SMF). This proposal has since been dropped. Download

FCA Call for Input on Open Banking

ABCUL responds to highlight the potential opportunities for credit unions which are beginning to offer services utilising open banking data whilst acknowledging concerns around data usage and the possible effects on the digitally excluded. Download

FCA & PRA Operational Resilience Consultations

ABCUL strongly supported withdrawing credit unions from the scope of these new requirements. ABCUL argues that it is disproportionate to subject credit unions a formalised regulatory framework designed for much larger firms where 24-7 access is expected. FCA PRA

FCA - Vulnerability guidance consultation

In this second stage consultation finalising vulnerability guidance, we broadly support the proposals on the proviso that the new guidance is supervised proportionately. Download

FCA - Guidance consultation on Branch and ATM closures & Conversions

ABCUL has published its response to the Financial Conduct Authority's guidance consultation on the measures that firms should take before closing their physical infrastructure. ABCUL has challenged both the proportionality and relevant of these measures for credit unions.. Download

PRA - FSCS: Extending Temporary High Balances Coverage

ABCUL has published its response to the Prudential Regulation Authority on extending the Temporary High Balances Coverage under the FSCS from 6 months to 12 months for a temporary period lasting until 31 January 2021. ABCUL also supported the proposal that credit unions need not update their FSCS disclosure requirements during the temporary period. Download

Removal of interest and charges from moratorium (Scotland)

Scottish Parliament Coronavirus (Scotland) No2 Bill has been subject to opposition amendments that would remove all interest and charges from any debt within a moratorium in Scotland for at least 6 months. ABCUL submitted views to the Parliament’s Coronavirus Committee on the matter. Download

Financial Conduct Authority - COVID-19 Payment Deferrals

ABCUL has published a response to a very short guidance consultation published by the FCA regarding emergency payment deferrals for unsecured loans. The vast majority of credit union loans are out of scope of these proposals, however, ABCUL has responded to push for further exemptions for the sector's consumer credit regulated lending whilst highlighting the positive forbearance approach taken by credit unions across the country. Download