In responding to  the PRA's consultation paper on implementing aspects of CRR2 in the UK we welcomed the certainty that the draft handbook text brings, as banks will have to implement the PRAs requirements by the beginning of next year .We raised a number of issues about the competitive impact of some elements of the proposals, for instance the inclusion of software assets in regulatory capital, the Standardised Approach to Counterparty Credit risk and  the use of the substitution approach in the large Exposures regime, as well as a range of more technical matters.