2 Feedback to responses
2.1 The PRA must consider representations that are made to it in accordance with its duty to consult on its general policies and practices and must publish, in such manner as it thinks fit, responses to the representations.
2.2 The PRA has considered the responses received to the CP. This chapter sets out the PRA's feedback to those responses, and its final decisions.
2.3 Overall, respondents welcomed the rationale for the new banks' buffer to facilitate the exercise of recovery options and supported the simplicity of setting it based on six months' operational expenses. A number of respondents welcomed the expectations proposed in the draft SS, including the maturity thresholds defined as a roadmap for the development of new and growing banks. Furthermore, respondents welcomed the emphasis on a 'clear path to profitability', and acknowledged that the PRA has rightly put a focus on profitability and expecting any new bank to be able to demonstrate that it has a sustainable and viable business model. The intention of the SWD was supported, recognising that it is a safe and efficient way for firms to exit the market in an orderly manner.
2.4 The chapters below have been structured broadly along the same lines as the chapters of the CP, with some areas rearranged to better respond to related issues. The responses have been grouped as follows:
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scope;
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expectations of new and growing banks;
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capital expectations of new and growing banks;
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orderly exit: recovery and resolvability; and
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the PRA's approach once banks are established.