UK Finance response to PRA consultation paper 26/23 - FCA consultation paper 23/30

Operational resilience: Critical third parties to the UK financial sector

The response highlights the importance of effective incident reporting by CTPs to both regulators and firms/FMIs. Aligning with emerging global standards like the Financial Stability Board (FSB's) FIRE proposals can streamline processes. Calibrating notification thresholds appropriately to avoid alert fatigue is crucial. Thorough testing of CTPs' resilience measures and playbooks, with firm/FMI involvement, is welcomed. However, aspects like selecting the representative firm sample and expanding testing scope to cover internal essential services need further consideration.