3.1 One respondent suggested that the PRA expectations for new building societies should benefit from the same gradualist approach that was proposed for new and growing banks. The respondent also said that some of the measures proposed (including SWD) for new and growing banks should be made available, where appropriate, to established (non-systemic) banks and building societies.

3.2 The PRA expects the arrangements for new and growing banks to apply equally to new building societies, but acknowledges that there may be areas of divergence, given they are subject to different legislation. The authorisation of new building societies will include the option of mobilisation and the expectation for SWD plans will apply. The PRA has amended the SS3/21 to reflect this (paragraphs 1.1 footnote 5 and 1.5 footnote 9). Furthermore, the PRA is considering whether it is appropriate that banks should maintain SWD plans beyond the point at which they move onto a PRA buffer set on a stress test basis. Therefore the PRA has deleted from paragraph 5.9 the text 'until they move onto a PRA buffer set on a stress test basis'. Further clarification will be provided in due course.

3.3 One respondent said the reference to 'mutuals' did not make it clear whether this includes or excludes mutual banks and other regional mutual banks currently being established. The respondent supported a phased approach for new and growing banks but recommended the end point for mutual banks should be an appropriately tailored regime.