UK Finance has responded to the  PRA's consultation on Credit risk: Probability of  Default and Loss Given Default estimation. Our response to this technically complex consultation paper encouraged the PRA to defer introduction of the modelling changes to residential mortgage portfolios and the application of the revised definition of default by one day to the beginning of 2021. We also noted that the focus of the CP is very much on mortgage portfolios and that for non-mortgage portfolios that are not specifically addressed in the CP, firms should be able to determine their own approaches, and asked the PRA to confirm that this is the case.