UK Finance support the direction of the changes and the specific amendments proposed to the Prudential Regulation Authority's (PRA) liquidity rules. We believe this update is necessary to align with the OPRR (Overseas Prudential Requirements Regime) and Basel 3.1 developments and ensure the consistency and workability of the framework.
 
We believe a consistent approach across the prudential framework is important to reduce uncertainty, avoid unnecessary fluctuations in outcomes, and ease the operational burden on firms. It also helps support international cooperation and the competitiveness of the UK financial services sector.
 
To help support consistent implementation across the industry and avoid unintended differences in treatment across firms, we seek greater clarity on any expectations the PRA may have for firm-led equivalence assessment for non-UK covered bonds.