Author: Chris Goodeve-Ballard
For those of you who had sat back, opened a bottle of Merlot and thought “phew – got that operational resilience stuff out of the way”, I’m going to wreck your day. By all means, finish your Merlot, but now the real work has to start.
The deadline from the PRA and the FCA of 31st March 2022 wasn’t the end of the project but the squeezing of the trigger on the starting gun. Identifying your Important Business Services, your Impact Tolerances, carrying out your mapping and producing your Self-Assessment document, merely got you to the starting line and into the blocks. You now have to become more granular in your approach and no later than 31st March 2025, be in a position where you meet your Impact Tolerances at all times.
As one sporting coach once said, amateurs practice until they get it right, professionals practice until they can’t get it wrong.
Both regulators want you to be a professional. This means that you now need to get into a cycle of reviewing your whole operational resilience stance. You need to test everything, refine and improve as necessary as well as ensuring all your key third party suppliers are doing the same thing. If they can impact on you working within your Impact Tolerances, you need to be on top of the situation and ensure they understand everything as well as you do.
The regulators are expecting to see continuous improvement and continuous action from you from 0100 hrs 1st April 2022. From that moment on, everything you did up to the initial deadline of midnight on 31st March 2022 is starting to degrade. A realistic testing and improvement programme must be in place which in turn will lead to regular updates of your Self-Assessment document.
While the rules say the Self-Assessment document must be updated when there are major changes or annually at the very least, any Operational Due Diligence review will expect it to be up to date.
Aldbury International can help you with the entire process as well as keeping your Self-Assessment documentation current and useful. Our dashboard will provide the evidence both regulators, investors and your Board needs to be confident that you haven’t ignored the starting pistol and are making genuine progress.
Call us on 020 3475 2953 and we would be happy to spend some time with you showing how we can help.