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06 March 2020

Considerations for Financial Services firms in relation to Covid-19

The FCA expects financial services firms to take all reasonable steps to continue to meet their regulatory obligations, and to have sufficient contingency plans in place to continue to operate their business and service clients (where relevant) in emergency scenarios, such as in the event of a widespread outbreak of Covid-19. The FCA’s statement is available here.

Regulated firms must have appropriate systems, resources and procedures in place to ensure continuity in the performance of their regulated activities. Key business continuity planning (BCP) rules are contained in SYSC 4.1.6 of the FCA Handbook and apply to most regulated firms.

Factors to consider for effective BCP include resource requirements (people and assets), firm operations, internal and external communications, escalation and invocation plans, processes to validate the integrity of information affected by any disruption, and regular testing of BCP policies.

A firm’s BCP planning and related systems, resources and procedures to cope with emergency scenarios should be proportionate to the nature and scale of their business i.e. large banks will be expected to have more extensive systems and controls in place than small businesses.

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