Response to consultation on draft Guidelines on the sound management of third-party risk

Question n. 1 for Public Consultation: Are subject matter, scope of application, definitions and transitional arrangements appropriate and sufficiently clear? 

yes

Question n. 2 for Public Consultation: Is Title II appropriate and sufficiently clear?

yes, except no. 37 lit. a: the criticality or importance of a function should not rely on the fact that parts of the function are provided by a TPSP. The criticality or importance of a function should only rely on the consequences for financial entities, e.g. financial or regulatory aspects.

Question n. 3 for Public Consultation: Are Sections 5 to 10 (Title III) of the Guidelines sufficiently clear and appropriate?

yes, just one comment regarding the evaluation of the costs for the TPSP (no. 63 lit. k / no. 64 lit. h). While the costs for TPSP not supporting a critical or important function can be estimated or retrieved as annual expenses, the costs for TPSP supporting a critical or important function shall be estimated for the last year. This looks like two different ways of estimating costs rather than estimating the costs for all TPSP in the same way.

Question n. 4 for Public Consultation: Is Title IV of the Guidelines appropriate and sufficiently clear?

yes

Question n. 5 for Public Consultation: Is Annex I, provided as a list of non-exhaustive examples, appropriate and sufficiently clear?

yes

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