Financial Trades Comment on Hong Kong Monetary Authority Operational Risk Management Proposals

Dear Raymond Chan,

The Asia Securities and Financial Markets Association (ASIFMAi), the Global Financial Markets Association (GFMAii), the Institute of International Finance (IIFiii) and the Bank Policy Institute (BPIiv) (collectively ‘the Associations’) welcome the opportunity to respond to HKMA’s new draft SPM module OR-2 on Operational Resilience, revisions to SPM module TM-G-2 on Business Continuity Planning and SPM module OR-1 on Operational Risk Management (‘Proposals’). The Associations recognise that these Proposals have been drafted and revised to more closely align with the Basel Committee on Banking Supervision (‘BCBS’) Principles for Operational Resilience[1] and the BCBS Revisions to the Principles for the Sound Management of Operational Risk[2].

The GFMA, IIF and BPI have been closely engaged with global standard setters and regulators on operational resilience for nearly four years working with our financial institution members through a joint Operational Resilience Steering Committee. Whilst ASIFMA has held the pen of this response which is substantially based on feedback from the Hong Kong (‘HK’)-based membership, the response also benefited from review and input from members of the GFMA/IIF/BPI Steering Committee so as to provide the HKMA with both local and international input in a single response.

Operational resilience is extremely important for the public and private sectors to maintain confidence in the financial industry and to support financial stability and economic growth. The Associations and their members acknowledge the importance of operational resilience for individual institutions, and across the financial sector, in support of customers, markets and the communities and broader economies they support nationally and globally. In support of this goal, our members recognise and appreciate the global coordination and alignment among policymakers and financial authorities on policy outcomes, terminology, and supervisory approaches.

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[1] The BCBS Principles for Operational Resilience (March 2021) can be found at:

[2] The BCBS Revisions to the Principles for the Sound Management of Operational Risk (March 2021) can be found at: