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Four months after the release of the UK supervisory authorities? operational resilience policy statements, UK Finance has continued its work with members to support their implementation and ensure that firms are appropriately prepared for the first major milestone in March 2022.
As part of the implementation, we conducted the first in a series of peer benchmarking surveys - to capture industry trends across all areas of the policy statements, and as a method for members to compare progress. Hearing from 70 members, the anonymised results gave firms a means to compare progress across the statements and helped shape a series of initiatives of the workplan.
The results provided good insight on general progress across the implementation phase of the statements. 46 per cent of organisations that responded are dual regulated, with 35 per cent setting materially different tolerances for Prudential Regulatory Authority (PRA) and Financial Conduct Authority (FCA) requirements. 54 per cent are headquartered in the UK and 28 per cent of organisations have a third country branch here. Reassuringly, all firms with a third-country branch in the UK intend to implement the policy statements.
Firms are well progressed in their classification of important business services. 39 per cent of firms have finalised their classification and 43 per cent have made progress in setting their associated impact tolerances. Due to the interrelated nature of the financial sector, setting impact tolerances is becoming an important issue and remains a focus area for collaboration and validation across firms.
Less progress has been made in the self-assessment; it is worth noting that 43 per cent of respondents have not started drafting their self-assessment yet. Only 35 per cent of firms are planning to have their first review of the self-assessment with their board or equivalent body by the end of 2021.
With only eight months left to implement the policy, the subsequent sessions will focus on mapping, scenario testing and the self-assessment with the 31 March 2022 deadline in mind. We look forward to continuing the work with our members and regulators throughout the implementation period.
Lorraine O'Donnell, Principal, Operational Resilience, UK Finance
Join the Risk and Resilience Academy for support and guidance on the new operational resilience policies. Registration now open.