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FCA Regulated fees & levies - rates proposals 2017/18

Response from ABCUL

ABCUL is the main trade association representing credit unions in England Scotland and Wales.  We appreciate the opportunity to respond to this consultation.

Having consulted with our membership, we are comfortable with the proposal to raise the minimum fee brackets by 1%.  This represents a relatively small increase and is below the rate of inflation.  However, we are slightly concerned at the proposal to link the minimum fee level in future to the Ongoing Regulatory Activity (ORA) fee level.  We are not confident that the FCA sees managing down costs and becoming more efficient as enough of a priority for there to be any realistic expectation that the ORA will do anything but increase going forward. 

Given that the range of developing regulatory expectations on firms is causing our membership to continually need to become more efficient in core processes in order to afford the rising cost of regulatory compliance and remain competitive, we are concerned that the FCA does not strongly-enough feel the same pressure to manage costs and reduce the burden of regulation upon the regulated industry.

On the other hand we appreciate and support the move to reduce the fee allocation to the deposit taking fee block and welcome the benefit that this will have for larger credit unions subject to the variable periodic fee.

We are pleased to see the significant reduction in the Pensions Guidance Levy and we support the maintenance of the level of the Financial Ombudsman Service.  Furthermore we are encouraged by and support the reduction in the costs of the Money Advice Service levies.

We have noticed a discrepancy in the fee calculator around how credit unions are charged for the MAS Debt Advice Levy and we understand that this is being investigated.  We look forward to an update in due course on the position here.