UK Finance has responded to the PRA's consultation on CRD V Further implementation (CP 17/20).

We generally supported the proposals but raised some implementation considerations, including focus on level playing field, on: holding companies, interest rate risk in the banking book (IRRBB), MDA and commercial real estate risk weights. We also took the opportunity to request clarity and engagement from the PRA on CRR2 provisions, including SA-CCR alpha factor, FRTB Standardised approach reporting, Net Stable Funding Ratio and Leverage Ratio.