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PRA - Regulated fees and levies: rates proposals 2017/18

Response to consultation

We respond to strongly support the continued policy of PRA holding steady the fee rates for minimum fees applying to credit unions, particularly the special lower minimum fees that the smallest credit unions enjoy. These fees are established as a measure of proportionality towards credit unions and in recognition of the valuable social role that they play in extending the availability of financial services to those at risk of exclusion.  It is also in line with the PRA’s statutory obligations to have regard for the effect of regulatory policy on providing a level playing field or otherwise in relation to mutuals and promoting competition.  We strongly support their maintenance for the coming fee year.

We are also encouraged to see the PRA make efforts to hold down the overall Annual Funding Requirement to a modest increase.  Since the split of the FSA into the PRA and FCA, the direct costs of regulatory supervision have increased markedly and, alongside the costs of banking failures via the FSCS, this places a drag on the activities of all regulated firms. The smallest firms feel this burden particularly acutely given their lack of economies of scale.

As ever, we would be happy to discuss this further or provide any additional feedback should that be required.