Operational Resilience is yesterday’s project, Consumer Duty is today’s. Right and wrong.
While the first Operational Resilience deadline was 31st March 2022 and Consumer Duty is a here and now issue, if you get the former right, it helps considerably with the latter.
You may well be trying to move your Operational Resilience into BAU, but it is still a very real issue because if you fail in this area, you most definitely will not be fulfilling any duty you may have to your consumers. In other words, it is the underpinning of everything you are trying to do as a business and everything the regulators want you to do as a business.
So, having established that, what should you be doing regarding Operational Resilience?
Test.
Test.
Test.
Even if you believe that you got everything spot on first time around, the rules require that you ensure everything is updated and reviewed at least annually (and more frequently if there have been changes to your business). The first thing you have to do to carry out a meaningful review is to test. The results of the test will either prove you were perfect first time around or (and let’s be honest here, more likely) you need to change a few aspects of your planning. This in turn feeds into your Self-Assessment Document. You then need to test again to ensure those changes actually work. It is an iterative process and only by testing in the first place, will you be able to prove that your review had teeth.
Teeth.
This brings up the subject of who should do the testing. Internal or external consultants. Internal will have the advantage of knowing the business intimately but almost always lacks rigour. A report by external consultants who have carried out your testing will always carry more weight with clients, regulators and investors.
Why Aldbury International? We are experienced at getting to know a client, finding scenarios that are plausible for the individual business but that will also stretch its Crisis Management Team. The upshot is they will have greater confidence in their ability to weather the storm – whatever form it may take.
The Aldbury team are all highly experienced in their own diverse fields and can bring a sense of realism to the exercise that no internal team will ever be able to replicate.