Response to EC Consultation on Digital Operational Resilience Framework for Financial Services

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.