Operational continuity in resolution – SS4/21
The brief
In 2021 the PRA published a revised OCiR policy (SS4/21) with the goal of ensuring operational continuity in resolution for banks. SS4/21 extends the definition of critical services to include services that are necessary for the continuation of core business lines. We were contracted by a leading global bank to lead them in updating their OCiR operation model and revise their approach for identifying critical services owing to the expanded scope of SS4/21.
Our approach
We have imposed a four-phased approach to aid the bank in meeting the regulatory deadline of 1st January 2023 with a hybrid delivery methodology to ensure ongoing remediation by the client would not be impacted. The four phases can be broken down into the following:
Definition: analysis was undertaken to identify the impact of the changes under SS4/21 versus the current processes, and to understand how the client can attest compliance to the PRA.
Gap analysis: a proof of concept was used to validate and test the methodology of changes to service mapping and assess how the scope is affected under the SS4/21 definition of critical services.
Design: documented changes to design principles whilst assessing the impact on the client’s current architecture and MI reporting.
Implementation: documented testing requirements, refreshed current run books / processes and design of transition to business as usual.
The solution and key benefits
As a result of this project, the client is able to demonstrate to the PRA that they can identify critical services received, and those required to deliver services to each of their critical functions and core business lines.
They are also able to demonstrate that they can put in place transition arrangements for the continuity of the critical services in the event of them being restructured or resolved.
