In advance of the new operational resilience requirements taking effect on 31 March 2022, UK Finance has highlighted the following key themes of importance to both customers and the FCA:
- Simplicity – customers expect outages to be resolved quickly and so many firms have simplified their approach to focus only on crucial processes that could cause customers undue harm. This approach assists the FCA in its effective supervision of the sector;
- Ownership – ineffective ownership may lead to reputational damage, regulatory fines and customer attrition so firms should ensure alignment to SMCR and establish clear ownership lines to facilitate early resolution;
- Vulnerability – vulnerable customers are at most risk of significant harm if a critical process fails. The FCA requires firms to evidence the steps they will take to identity and protect these customers;
- Third parties – it is unclear how amenable third party suppliers will be to the level of oversight, control and reassurance firms may seek relating to documentation of end-to-end processes, management information and input to tolerances, and intervention by the FCA may be required; and
- Data – firms that are still developing their data strategies should document their current capability to monitor, measure and articulate the improvements they have identified as a key part of their emerging data strategy.