Response to EC Consultation on Digital Operational Resilience Framework for Financial Services
March 19, 2020
On March 19, MFA responded to the European Commission Consultation Document Digital Operational Resilience Framework for financial services: Making the EU financial sector more secure. Notably, MFA raised two general comments for the Commission’s consideration:
First, MFA urged policy makers to enhance operational resilience of financial services by building off of the existing regulatory framework, not by creating a new framework; and,
Second, MFA stressed that the European Commission enhance the public sector’s stewardship of sensitive financial services data using a three-step approach: regulators and supervisors should tailor reporting requirements to ask for only the data that is necessary to achieve their function; protect the data using alphanumeric identifiers rather than names and other identifying information; and tier their protections and security protocols based on the level of sensitivity of the data.