Continuity of access to FMI services (FMI intermediaries) for firms in resolution: Framework for information from FMI intermediaries to support resolution planning
Access to FMI services is essential for banks to be able to continue performing their critical functions or critical services under all circumstances, including in cases where banks need to be resolved.
In 2017, the FSB published its Guidance on Continuity of Access to Financial Market Infrastructures for a Firm in Resolution. The Guidance sets out arrangements and safeguards to facilitate continuity of access to FMI services for a firm in resolution with a view to maintaining the firm’s critical functions that rely on the continued access to FMI services. As part of implementing the Guidance, authorities and firms (as FMI service users) develop plans to facilitate continuity of access in resolution. This requires information about the nature of the FMI service user’s relationship with both FMIs and FMI intermediaries on the arrangements and safeguards that would affect an FMI service user’s access to FMI services in the run-up to, and during, its resolution.
Following a workshop held in May 2019 with stakeholders about the implementation of the Guidance, the FSB developed a questionnaire for FMIs to aid resolution planning for firms that use FMI services and their resolution authorities (RAs), which has now been revised. FMI intermediaries were out of scope of that questionnaire, in view of the more bespoke nature of their relationships with FMI service users.
Following on from this, the FSB has considered how it can most effectively support firms and RAs in accessing the information they need from FMI intermediaries to prepare their resolution plans, and how it can support FMI intermediaries in meeting the needs of their clients and their clients’ RAs.
The framework set out in the document published today seeks to help FMI intermediaries better understand which information clients and their RAs may need from them. It does so by providing an overview of the baseline information that is potentially relevant for clients and RAs, which they and FMI intermediaries can then discuss, as needed, in their bilateral engagement. Thus the framework makes it more predictable for FMI intermediaries which topics could be part of information requests from their clients and/or from their clients’ RAs. This could potentially allow them to identify opportunities to streamline their response process, reducing the resources required to provide this information.
As part of our outreach, the FSB will host a webinar for stakeholders on this Framework on 16 September 2021. Representatives of FMI service providers, FMI service users and authorities who would like to attend should contact firstname.lastname@example.org for more details.