UK Finance response to the Bank of England and PRA’s CP 9/23

UK Finance has responded to the Bank of England and PRA’s consultation paper 9/23 on proposed changes to its approach to enforcement.

We support the intention of the proposals, which clarify the framework for proactive investigation and   could speed up the information gathering process and conclusion of a PRA investigation. But we raised concerns about the tight 6-month timeline for delivering Early Account Scheme materials and the requirement for a Senior Manager to attest that the information provided is complete, as well as concerns about loss of legal privilege.

Bank of England and PRA’s consultation paper 9/23