In line with their promise to deliver a Policy Statement for Operational Resilience by the end of Q1 2021, the FCA and PRA hit a buzzer-beating submission with their outputs this morning.
The Policy Statement itself does not diverge significantly from what was already published in draft in their previous Consultation Paper. However, the use of expanded examples and a number of clarifications are extremely helpful for the reader to continue to understand the regulators’ expectations in this area.
There were two more material changes within the Policy Statement, these being:
- During the implementation period which runs to 31 March 2022, firms will only need to carry out mapping and scenario testing to a level of sophistication necessary to accurately identify their important business services, set impact tolerances and identify any vulnerabilities in their operational resilience.
Following this initial output stage, firms will be required to scenario test and mature their mapping over the next few review cycles to the end of the full transition period (31 March 2025).
- Scenario testing frequency has been changed from annually to ‘upon material changes, following improvements by the firm, or in any event, on a regular basis’.
With the Operational Resilience Policy Statement now out, delivery can fully begin on a no-regrets basis.
For further information, FourthLine have prepared an Operational Resilience insights pack that you can download here>