IIF-AFME comment letter on the UK PRA discussion paper on operational continuity in resolution

On January 6, the IIF and AFME (together, "the Associations") jointly submitted a letter to the UK Prudential Regulation Authority ("PRA") on the discussion paper "Ensuring operational continuity in resolution", commenting on the PRA's preliminary views on the principles that firms' operational arrangements must satisfy in order to facilitate recovery actions, resolution, and post-resolution restructuring.'

The Associations welcome the guidance on operational continuity criteria in order to achieve the objectives of establishing credible and effective resolution plans and of preparing for resolution with minimum disruption, with some reservations about the ambiguity of definitions and more need for global coordination and cooperation.'  The Associations consider defining "critical shared services" in line with the FSB guidance would be desirable.'  Some of the proposed criteria were not clear as to how they would be applied to divisions within firms and whether the criteria would provide sufficient flexibility in permitting different firm structures to achieve the desired goals.' '  The Associations also stress more need for global coordination and cooperation, which should be built in to the guidelines.'  It is essential that operational continuity guidelines be led by and tailored to the relevant group resolution plans through Crisis Management Groups.