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Meeting of the minds: Global regulators converge on operational resilience

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At the end of March, the UK’s Bank of England (BoE), Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) published their final Policy and Supervisory Statements on Operational Resilience followed shortly after by the Basel Committee on Banking Supervision (BCBS) publishing its final Principles for Operational Resilience. Both documents are consistent with the tone and content found in their preceding discussion papers, from December 2019 and August 2020 respectively,[1] but the UK regulators slightly eased their implementation timeline[2] and BCBS clarified the details of some of their principles.

These publications build upon a growing global regulatory emphasis on operational resilience that also extends to the US where the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) published a joint paper last October outlining sound practices to strengthen operational resilience.[3] Taken together, these publications reflect a similar mindset that resilience needs to continue to improve across the board, with yet some divergence in their approaches: with prescriptive requirements from the UK regulators, and principles from the BCBS and sound practices from the US agencies that are rooted in existing regulatory guidance but do not create new formal requirements.

Despite these differences, we see these releases collectively as part of a consistent global push to make resilience a core aspect of how banks think about operational risk, and how they construct and evolve their operating models globally while conforming to local requirements of varying nature and levels of prescriptiveness.

This Regulatory Brief outlines elements of convergence and divergence across the different regulatory publications and provides our perspective on what financial institutions should do next.

Regulatory brief

A publication of PwC's financial services regulatory practice

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Julien Courbe

Financial Services Leader, PwC US

Dan Ryan

Partner, PwC US

Adam Gilbert

Financial Services Advisory Regulatory Leader, PwC US

Roberto Rodriguez

Director of Regulatory Strategy, PwC US

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