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

FCA Quarterly Consultation - Consumer Duty Policy

ABCUL responds to the Financial Conduct Authority's quarterly consultation paper, to raise issues related to credit union's implementation of the Duty. Download

PRA – Changes to the Credit Union Regulatory Regime

ABCUL responds to the Prudential Regulation Authority’s proposals to amend its regulatory regime for the credit union sector. Download

The Insolvency Service – Review of the Personal Insolvency Framework

ABCUL responds to the Insolvency Service’s Call for Evidence on the Personal Insolvency Framework. Download

HM Government – Consultation on Dormant Assets Funding

ABCUL responds to the Government’s consultation on the English portion of the Dormant Assets Scheme funding. Download

Financial Ombudsman Service – Creating a Funding Model for the Future

ABCUL responds to the Financial Ombudsman Service’s discussion paper on its future funding model. Download

HM Treasury – Consultation on the Statutory Debt Repayment Plan

ABCUL responds to HM Treasury’s consultation on implementing the Statutory Debt Repayment Plan. Download

The Insolvency Service – Future of Insolvency Regulation Consultation

ABCUL responds to the Insolvency Service’s Consultation on the future of insolvency regulation. Download

HMRC - ISA Compliance and Penalties Call for Evidence

ABCUL responds to HM Revenue & Customs Call for Evidence on 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