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

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

Financial Conduct Authority - Quarterly Consultation: The directory

ABCUL has responded to this quarterly consultation to support the techincal amendments introduced to the FCA handbook regarding the classification of credit union certification functions. We have also provided some feedback on the overall process of providing the required information on Directory scope individuals to the FCA. Download

ABCUL Responds to FCA Regulatory Fees Consultation

The Financial Conduct Authority (FCA) consults annually on changes to the fees policy for the next fee year, credit unions were briefed back in November about the proposal to introduce an £50 administration fee for paper invoicing. In addition FCA stated that they are looking to reform the structure of the debt advice levy which most credit unions are currently exempt from paying. ABCUL has responsed to the proposals. Download

Scottish Parliament Economy Committee Protected Trust Deeds Inquiry - January 2019

ABCUL responded to the Scottish Parliament's inquiry into the use of Protected Trust Deeds in Scotland. Download

Prudential Regulation Authority - Credit unions, review of capital regime - response from ABCUL

ABCUL has submitted our response to the PRA’s proposals for reform of the capital requirements Download

HM Treasury - Call for evidence - Future of financial regulation

ABCUL responded to the HM Treasury's call for evidence on the future of the regulatory framework for financial services. In our response ABCUL pushes for legislative reform of the Credit Unions Act to more clearly define the extent of which credit unions can provide different kinds of financial services. ABCUL also makes the case for a continuation of proportionate regulatory exemptions for credit unions post-Brexit and the seperation of the Mutual Societies Register function from the FCA due to it's ineffectiveness and the conflicts of interest that arise between it and the regulatory functions of the FCA. Download

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