Eversheds Sutherland advises the Association of Foreign Banks on operational resilience consultation

Eversheds Sutherland has supported the Association of Foreign Banks (AFB), and its member banks, on its response to the Bank of England, Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) co-ordinated consultation papers (CPs) on new UK requirements to strengthen operational resilience, and manage the risks of outsourcing and third party supplier arrangements in the financial services sector.

The team at Eversheds Sutherland, led by Partners Craig Rogers and Jake McQuitty, worked closely with the AFB and key stakeholders within the AFB member banks.

The AFB’s membership includes some of the world’s largest banks and their UK branches and subsidiaries. It also includes smaller retail, wholesale and investment banks with headquarters in jurisdictions outside the UK. As such, one of the key objectives of the response to the CPs was to ensure that the regulators recognise and take account of the particular operating dynamics of this cohort of banks.

The AFB response to the CPs was issued in October 2020 and the firm anticipates the final Policy and Supervisory Statements being published in early Q2 2021.

Links to the CPs can be found at the following links on the FCA and PRA websites:

FCA CP19/32: Building operational resilience: impact tolerances for important business services

PRA CP29/19: Building operational resilience: Impact tolerances for important business services

PRA CP30/19: Outsourcing and third party risk management