Laura WilesFollowing its October 2022 survey of banks, FMI intermediaries and FMIs about their experiences with its resolution planning framework, FSB has published a statement on continuity of access to FMI services for firms in resolution.
The framework and questionnaire were developed to assist FMI service providers in identifying information that is potentially relevant for resolution planning for clients and resolution authorities. FSB highlights how recent crises have reinforced the need for banks to be resilient in this area.
Responses to FSB’s survey indicated that its guidance is seen as a helpful reference, but further uptake by FMIs and intermediaries is needed. Some FMI service providers sought feedback on their questionnaires from the users of the information and one respondent noted that FMI service providers as well as banks have information needs to support their own contingency planning.
FSB concluded that its existing framework and questionnaire on continuity of access to FMI services in resolution do not currently required revision. However, its response provides certain clarifications to further support information exchange between service providers and service users for contingency planning purposes, including:
- FMI service providers should be ready to respond to client inquiries about continuity of access to their services;
- The onus is on the firm to identify which FMI services it procures are critical for its continued operation in a crisis or resolution;
- FMI services provided by FMIs owned and operated by central banks are within the scope of the FSB guidance where it concerns their participants’ need for information;
- If the relationship between the firm and its FMI service provider is bespoke instead of based of rulebooks, the firm may need to address detailed questions to the service provider; and
- Some questions in the questionnaire and framework that may appear duplicative are listed intentionally as separate questions.