UK financial sector operational resilience consultation: BCM nirvana or nemesis?

Published: Tuesday, 27 November 2018 23:25

Steve Dance looks at how the ‘Building the UK financial sector’s operational resilience’ Discussion Paper (DP) could impact BC managers in the UK financial sector.

Earlier in 2018, the UK Bank of England, Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) published a joint Discussion Paper on an approach to improve the operational resilience of firms and financial market infrastructures (FMIs). The consultation closed in October.   

You might think that the above Discussion Paper constitutes manna from heaven for business continuity managers in the financial sector – at last a good slug of regulation to add weight and focus to a financial firm’s business continuity programme. A reading of the DP, however, soon reveals that the regulatory direction of travel could marginalise business continuity and evolve it into something else. Regardless of what name we might want to give it, the thrust toward resilience as an overarching goal will require different thinking within the financial sector business continuity community.

The nirvana effect will come from the fact that the regulatory agenda naturally becomes part of the management agenda, which will create a trickle-down focus on the subject. This is (probably) a good thing for the business continuity function because it will achieve some mindshare in the upper echelons of management. The word ‘probably’ is used because the nirvana depends on one thing – that the BCM function actually steps up to the plate and becomes a ‘player’ in preparing their organization to be ready to comply with any new regulations.

The nemesis option could manifest itself in a couple of ways:

The major challenges for financial firms in adopting and complying with the proposals contained in the current DP will include:

The response stage for the Discussion Paper is now complete and it is now moving towards its next stage which is the Consultation Paper: the clock is ticking…

The author

Steve Dance is Managing Partner of RiskCentric.