This response represents the views of European CCPs on the discussion paper of the UK Prudential Regulation Authority, Financial Conduct Authority and the Bank of England on 'Building the UK financial sector’s operational resilience'. In summary:
- From disaster recovery to service resilience – EACH supports the supervisory authorities’ approach to change focus from system ‘Disaster Recovery’ to service resilience.
- Impact tolerances not an exact point of no viability but rather early warning – EACH supports the set-up of impact tolerances for all financial sector firms and FMIs. We would caution against trying to set tolerance by attempting to establish the exact point at which the financial sector firm or FMI will not be viable due to a failure. We suggest tolerances set around key activities to be an early warning allowing the FMI to take appropriate action to avoid any failure leading to the FMI not being viable.
- Support for preventative and defensive measures – Any risk management framework would need to look at ‘preventative’ or ‘defensive’ measures that are in place.
For more information, please find attached the EACH response or visit the EACH website www.eachccp.eu
