UK Finance has responded to the PRA's CP9/20, which makes proposals about the PRA's approach to supervising fast growing banks.

Our response supports a more proportionate approach to the supervision of non-systemic banks and the  simplicity of the proposed new approach to setting the PRA buffer prior to moving to a stress test basis. We suggested that setting a firm's  PRA buffer based on six months operating expenses could for some banks,  depending on their business model, result in a disproportionate increase in overall capital requirements. We instead suggested that the six months operating expenses should be moderated to focus only on the costs of those activities  that would be required to maintain the continuity of critical services for its expected customer base over the six month period.