Status: Draft -- Not PublishedWill be live at 01/04/2016 00:00
IIF CBRWG Response to the FSB's Consultation Paper on Operational Continuity
The joint comment letter on the Guidance on Arrangements to Support Operational Continuity in Resolution stressed the importance of flexibility in assessing arrangements for continuity of essential functions, to reflect each institution's going-concern business model and resolution strategy, and underscored the importance of the FSB's doing the maximum to assure cross-border cooperation among resolution and supervision authorities in planning for operational continuity. It also emphasized that, while planning for the costs of operational continuity is highly important, such planning should be based on the resolution plan and not require excessive resource based on open-ended projections. It also suggested that the final guidance should be somewhat less granular and prescriptive, and rather should stress the need for the firm to explain how its arrangements would support the required operational continuity in the facts and circumstances of its business model and resolution planning. Finally, it noted the need for balance and proportionality in planning for operational continuity in resolution while not unduly burdening the firm's ability to conduct business-as-usual activities.