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UK Finance response to the PRA Consultation Paper (CP29/19) Operational Resilience: Impact tolerances for important business services and the FCA Consultation Paper (CP19/32): Building operational resilience: impact tolerances for important business services and feedback to DP18/04
UK Finance has responded to the UK authorities? co-ordinated consultation papers on operational resilience on behalf of its members. Our response endorses a number of the proposals designed to strengthen operational resilience in the UK's financial sector. These align with the sectors long term belief that operational resilience, is as important, as financial resilience.
Any efforts to improve operational resilience should be based on four overarching principles, namely collaboration, proportionality, international alignment, and ongoing guidance. We encourage the authorities to consider and apply these across the constituent elements of operational resilience.
In addition, there are a number of ways the proposals can be improved. We suggest that, in order to avoid unnecessary complexity and cost, dual-regulated firms are not subject to multiple impact tolerances. We also ask that the finalised policy clarify that regulatory reporting is not a business service and is therefore a separate obligation outside the scope of requirements.
We look forward to continuing to work in collaboration with the regulators and our members on this important area.
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