Consultation Responses

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

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

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

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

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

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

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

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

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

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

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

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

ABCUL submitted a response to the Insolvency Service’s Call for Evidence. A many members will be aware, we have been calling for some time for significant changes to the regulation of this sector, and we were pleased that the Insolvency Service launched a Call for Evidence on the matter earlier this summer. Download

In addition to this, we also co-ordinated a joint letter with the other 4 credit union trade associations, which noted the fact that the whole sector is united in its concern about this issue Download