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Bank of England & Prudential Regulation Authority - Approach to EUWA reforms

Response to consultation

We respond to this consultation in parallel to our response to consultation CP 26/18 and in relation specifically to the question of temporary transitional relief as outlined in Chapter 4. We refer you to our response there for further details on the potential impact of the requirement to repatriate funds for credit unions post-exit day.

We are encouraged by the pledge that the PRA will utilise its temporary transitional power to allow credit unions to continue to hold these deposits for a period of time after exit day to allow for a smooth transition to the new regime. We strongly support this proposal which could be critical for a small number of credit unions.

We would like to see the PRA pursue this intended course and to provide further details as soon as possible as to how long the transitional relief might last, the conditions it intends to attach to its use, any additional reporting that may be required for those enjoying the relief and the means by which firms might apply. It is imperative that conditions attached to relief are proportionate and appropriate to the size of firm and the relative risk inherent in granting the relief.