The FSB emphasizes the significance of continuity of access to FMI services for banks, especially during resolution. The FSB Framework and Questionnaire were designed to help FMI service providers gather relevant information for clients and resolution authorities to support resolution planning. Survey feedback in October 2022 indicated that the FSB guidance is valuable, but more uptake by FMIs and FMI intermediaries is needed.
The FSB believes that its existing publications on firms‘ continuity of access to FMI services do not require revision. However, the present document offers clarifications to enhance information exchange between FMI service providers and users for contingency planning. While many internationally active FMIs have responded to the FSB Questionnaire, the FSB urges all FMIs to do so and update their responses periodically for accuracy and usefulness.
Stakeholders stress the importance of FSB guidance as a reference for increasing preparedness for contingencies, while FMI service providers seek more feedback on their Questionnaire responses. FMI service providers must be prepared to respond to clients‘ inquiries about access to their services, including clearing, payment, securities settlement, or custody services.
The onus lies on banks to identify critical FMI services they require for continued operation during a crisis or resolution. FMIs owned by central banks should provide relevant information to their participants. The Framework for information from FMI intermediaries assists clients in contingency planning, especially when bespoke relationships exist.
Some respondents noted potential duplications between the Questionnaire and Framework, but they serve distinct purposes and phases of the crisis continuum. Tailored arrangements may limit FMI intermediaries‘ standardization or publication of responses, making the Framework more appropriate.
The FSB encourages the use of the Questionnaire and Framework by stakeholders beyond banks to enhance contingency preparedness. Stakeholders may seek additional information through bilateral discussions with FMIs or FMI intermediaries.
The FSB remains open to stakeholder input and may consider future changes to the Framework to facilitate information exchange for contingency planning related to FMI services.