On March 14, the IIF, GFMA and BPI submitted a comment letter to the International Organization of Securities Commissions (IOSCO) in response to its Consultation Report on Operational resilience of trading venues and market intermediaries during the COVID-19 pandemic. The response was informed by feedback from members of the IIF Steering Committee on Operational Resilience.

The joint trade associations’ comment letter recognizes the importance of operational resilience for both the public and private sectors to maintain confidence in the financial industry and to support financial stability and economic growth. We encourage IOSCO to align its definitions of operational resilience with those used by the Basel Committee on Banking Supervision (BCBS) to increase alignment and coordination across the financial system globally.

In the letter provides feedback on IOSCO’s questions related to the operational resilience experience during the COVID-19 pandemic highlighting the importance of public/private collaboration during stress events, the significance of third-party dependencies and specific experiences and trends related to the pandemic (for example, related to remote working arrangements). We also emphasize that, while the COVID-19 experience is naturally top of authorities’ and firms’ minds at present, any IOSCO efforts around operational resilience should be capabilities-driven and agnostic towards exact scenarios. No one can predict the next event, and flexibility is required to respond appropriately to a range of possible disruptions.