Posted on: May 20, 2025
Building Societies’ Treasury & Lending Activities – Supervision Discontinuation
The Prudential Regulation Authority (PRA) issued consultation paper 11-25 in which it proposed the withdrawal of restrictions placed on Building Societies’ Treasury risks and lending. The limitations are detailed in Supervisory Statement 20-15 (SS 20-15). Assuming this proposal is introduced, the applicability of that document will not apply from 1st January 2026. The change will mean that the various approaches (i.e. ‘Administered’, ‘Matched’, ‘Extended’, ‘Comprehensive’) to financial risk and Treasury, will not be relevant to the Building Society sector. As part of that adjustment, lending limits akin to each business model, will be removed. The benefit of removing SS20-15 is the opportunity to increase competitiveness in financial services.
Consumer Credit Regulatory Return CCR009
The Financial Conduct Authority (FCA) issued policy statement 25-3 (preceded by consultation paper 24-19), regarding introduction of a new regulatory submission, CCR009. Completion of the return will be required by firms that:
- Engage in credit broking, debt adjusting (e.g. re-scheduling over an extended period), debt counselling, debt solutions (e.g. bankruptcy, equity release) and credit information services AND
- Have consumer credit outstanding balances of at least £2million and / or new lending of the same amount.
The regulator has proposed that alongside the introduction of this template, will be the withdrawal of CCR004, CCR005 and CCR006. Forms CCR002 and CCR007 will have reduced reporting requirements.
The first report reference date will be 31st December 2025 and cover the full calendar year. Institutions that will be required to submit data and have consumer credit related regulated annual revenue above £5million, will do so on a semi-annual basis (the first six month period is 1st January 2026 to 30th June 2026). Those entities with lower revenue, will provide the information annually. All affected firms will report for the full calendar year of 2025.
CryptoAssets Regulation
The FCA issued a Discussion Paper (DP 25-1) about the regulation of cryptoassets. This paper follows on from earlier publications DP 23-4 (fiat backed stablecoins) and DP 24-4 (disclosures and market abuse) on the topic. Of note in DP 25-1 is the importance of retail consumer protection. It is suggested that such consumers not be permitted to undertake cryptoassets borrowing and lending. Also, any trading platform to be available to UK retail customers (non-professional investors), be authorised by the regulator. Further publications on the regulation of cryptoassets are expected this year. Clearly, the regulator sees this area as high risk and makes the point that investors should be prepared to lose all of their investment.
Small Domestic Deposit Takers’ (SDDT) Regime
According to the PRA Business Plan for 2025-26 (and the initiatives grid published in April 2025), the capital requirements (and any other liquidity simplifications) under SDDT will be finalised and published in Q4 of 2025.
The implementation date of the Small Domestic Deposit Takers Regime will be advised at the same time.
Step-in Risk Reporting
The PRA issued its policy statement 5-25 (follow on from consultation paper 23-23) about step-in risk. The reporting will be effective from 1st January 2026 and be under Banking Taxonomy 3.8.0. The new reporting requirements will be applicable to banks, building societies and PRA regulated investment firms. According to paragraph 1.2 of the policy statement, firms that are to be subject to the Small Domestic Deposit Takers’ Regime, will not be required to submit step-in risk data.
WIRES Releases
The current planned release of Whistlebrook’s regulatory reporting system, WIRES, is below.
| Reference | Content | Estimated Date |
| 7.0 | Minor enhancements | 30th June 2025 |
This regulatory update is Whistlebrook’s understanding of the position as at 19th May 2025.