FSA - CP 12/28 - Regulatory fees & levies: policy proposals 2013/14
Summary of ABCUL’s position
ABCUL supports the general approach to fees and levies policy in transition to the new regulatory structure. We are particularly supportive of the fact that, at least initially, the minimum fee settlement which credit unions enjoy is to be retained and the PRA Transition costs fee-block will raise fees only from those firms which exceed the minimum fee threshold. These are measures which will make a significant contribution to the proportionality of the fee arrangements in transition.
Though we appreciate that fee policy and fee levels post ‘legal cutover’ (LCO) will be a matter for the PRA and FCA to set, we would urge strong consideration to be given to ensuring a proportionate regime is maintained for small dual-regulated firms such as credit unions. It is vitally important to the continued development of the credit union sector that regulatory fees are not allowed to increase substantially simply through the creation of the twin peaks regulatory model. While we accept and appreciate the need for both bodies to fund themselves, it would act against the overall Government policy for increasing diversity and competition in financial services if a small but growing sector such as ours were to be impeded by spiralling regulatory fees. To this end the proposed acknowledgement of the need to consider the special needs of dual-regulated firms in the proportionality principle of the FCA fees governing principles is very welcome.
The full response can be downloaded on the right hand side.