On the 17th of December 2021, the Central Bank issued the above statement. They received feedback from 21 respondents on the paper. The Central Bank looked at each response in detail.
The topics listed below were identified as items where feedback, amendment or further clarification is warranted:
- Alignment with existing guidance from the European Supervisory Authorities (ESAs)
- The Principal of Proportionality
- Application of the Guidance to branches and the funds sector
- Intragroup Arrangements
- Sub-Outsourcing
- Contractual Arrangements and SLAs
- Disaster Recovery, Business Continuity Management & Exit Strategies
- Audit and Access Rights
- Concentration Risk
- Offshoring
- Board Oversight
Each of the points above has further comment from the Central Bank in the statement. It should also be noted also that the Central Bank states ‘Where existing relevant sectoral legislation, regulations or guidance is less prescriptive or is silent on certain matters, it is the Central Bank’s expectation that regulated firms refer to the supervisory expectations set out in this Guidance, which is deemed good practice in the governance and management of outsourcing risk.’
The feedback statement and related guidance are essential reading for regulated financial service providers that outsource any activities. Have you got systems and controls in place in your firm?
Central Bank of Ireland: Cross Industry Guidance on Outsourcing