Clare McMullen, Rebecca Heaysman and Simon Treacy share some feedback from the FCA on firms’ readiness for the UK operational resilience rules.
Clare McMullen, Partner: “You have to remember that the first time the regulator picks up this self-assessment document could be in the wake of an incident.”
Episode 8: Asset managers’ readiness
Raza Naeem, Clare Wiles and Simon Treacy assess how prepared the UK asset management sector is for operational resilience rules to take effect.
Raza Naeem, Counsel: “At this stage and over the next year or so there’s still time to pin down that legal analysis and recalibrate if necessary.”
Episode 7: The approach in Hong Kong
Sumit Indwar, Eugénie Levy and Kishore Bhindi discuss the SFC’s circular on operational resilience and remote working and how the Hong Kong approach compares with the UK regime.
Sumit Indwar, Partner: “Firms may already have much of this in place, but it will be a case of clearly documenting and flagging those measures as part of their operational resilience plans.”
Episode 6: EU plans for DORA
Florian Reul, Kathrin Hafner and Simon Treacy discuss the EU’s draft Digital Operational Resilience Act, known as DORA.
Florian Reul, Managing Associate:“DORA is providing a game plan on how to become better at addressing ICT risks.”
Episode 5: Important business services
Pansy Wong, Rebecca Heaysman and Simon Treacy examine important business services and how to identify them.
Pansy Wong, Partner:“In our experience there’s a feedback loop, so once you work through the other operational resilience obligations you may find yourself revisiting your approach to how you identified those important business services in the first place.”
Episode 4: The final rules – What we know now
The UK regulators have finalised their operational resilience regimes. Clare McMullen, Verity Kemp and Simon Treacy compare the final rules with the draft rules.
Clare McMullen, Partner:“How firms treat vulnerable customers fairly is a real priority of the FCA at the moment and so it is not a surprise that they have added express references to vulnerable customers in their guidance on operational resilience.”
Episode 3: Backstage at OpRisk Global
Julia Dixon, Pansy Wong and Simon Treacy share their insights from the OpRisk Global conference which took place virtually in March 2021.
Pansy Wong, Partner:“Plenty of people I spoke to were worried about what it means that different standards are developing in different jurisdictions. And even though the overall aim of all these different regimes is the same, the nuances between them will inevitably cause headaches for global firms.”
Episode 2: Back to the future
Pansy Wong, Rebecca Heaysman and Simon Treacy look back on what has changed since the UK regulators released their draft rules on operational resilience in December 2019.
Pansy Wong, Partner: “It would be a real surprise if the outcome of all the policy work that has happened in the background isn’t influenced by the events that have taken place since the consultations were launched… All of that said, Covid-19 has been a really unusual source of disruption.”
Episode 1: The basics of operational resilience
Julia Dixon, Verity Kemp and Simon Treacy introduce the concept of operational resilience and what it means for UK financial services.
Julia Dixon, Partner: “The reforms are really signalling a cultural change, a shift in terms of how firms need to approach resilience and there’s going to be regulatory attention focused right at the top of the house on how you are approaching this subject.”