By Pooja Bokhiria
On 6 May 2021, the Financial Conduct Authority (the “FCA”) clarified its expectations regarding firms’ obligations to review their legacy outsourcing arrangements in line with the European Banking Authority’s guidelines.
Under the guidelines, firms are required to review critical or important outsourcing agreements entered into before 30 September 2019. Those that have not finalised their review by 31 December 2021 must inform their competent authority and provide information on the measures planned to complete the review or the possible exit strategy.
Following the United Kingdom’s departure from the European Union, firms will be expected to continue following the guidelines but will not be expected to report on their progress to the FCA. Instead, they should aim to review any outstanding critical or important outsourcing arrangement or revision point. If these outsourcing arrangements have not been finalised by 31 March 2022, the FCA should be informed.
Further information on this can be found here.