UK Finance has responded to PRA's consultation proposing to apply the group provisions in the Operational Resilience Part of the PRA Rulebook relevant to Capital Requirements Regulation (CRR) firms to holding companies.

We very much support this initiative which is consistent with an enterprise-wide approach to operational resilience and will require the Holding company of CRR  firms to take the primary responsibility for ensuring the operational resilience of its group. This and preferable to the current obligation  that imposes that obligation on individual firms and  which can now be corrected as a result of changes to the Financial Services and Markets Act.

We noted an apparent inconsistency between the draft wording proposed for the Supervisory Statement and that of the PRA Handbook, which if uncorrected could imply an obligation on the CRR holding company to look out from its immediate group into a wider non CRR group to identify Important Group Business Services.