Response to consultation on draft Guidelines on the sound management of third-party risk
Question n. 1 for Public Consultation: Are subject matter, scope of application, definitions and transitional arrangements appropriate and sufficiently clear?
NA
Question n. 2 for Public Consultation: Is Title II appropriate and sufficiently clear?
With reference to paragraph 33 of the consultation paper, we would like to gain a deeper understanding of how to correctly interpret the role of the risk assessment of third-party arrangements (as described in Section 11.2) in determining whether a function should be considered critical or important.
In particular, what could be the key criteria and operational approaches to evaluate the potential impact of an arrangement with a TPSP on the relevant risks faced by the financial entity (including operational, reputational, legal, and concentration risks)?
How should this assessment guide the classification of a function as critical or important, taking into account its effects on regulatory compliance, financial performance, and service continuity?
Question n. 3 for Public Consultation: Are Sections 5 to 10 (Title III) of the Guidelines sufficiently clear and appropriate?
NA
Question n. 4 for Public Consultation: Is Title IV of the Guidelines appropriate and sufficiently clear?
NA
Question n. 5 for Public Consultation: Is Annex I, provided as a list of non-exhaustive examples, appropriate and sufficiently clear?
NA