BPI in coordination with the American Bankers Association submitted a joint comment letter to the Basel Committee on Banking Supervision in response to the BCBS’s August 2020 consultative document, Principles for operational resilience, which would articulate a principles-based approach to improving operational resilience for the purpose of strengthening the ability of banks to withstand operational risk-related events that could cause significant operational failures or widescale disruptions in financial markets, such as pandemics, cyber incidents, technology failures or natural disasters. BPI and ABA strongly support the efforts of the international community to address this important issue; however, they strongly believe that as a supervisory matter, operational resilience is best addressed through a framework that is based on broad principles and flexible to individual firms’ established programs and practices. The joint trades support the extent to which the Proposal seeks to articulate foundational principles for operational resilience and avoid imposing specific and prescriptive mandates. To that end, the comment letter identifies a range of suggestions which would further align the Proposal with its stated principles-based approach.
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