UK Finance has responded to the Basel Committee's consultation on its consolidated framework document. We were in broad agreement with the mainly reformulated document but recommended that BCBS withdraws the proposal to implement an interim floor, based on the current standardised requirements. Instead, given the imminent 2022 introduction of the Basel 3.1 framework we suggested that  the current arrangements already set up by the national supervisors should continue.

We also pointed out that the current Basel standards use 'special purpose entity? (SPE) and 'special purpose vehicle? (SPV) interchangeably and without making a clear distinction between the two. To promote consistency across the framework, we suggested the replacement of all references to SPVs with SPEs.