Recovery Planning under ECB supervision

SUMMARY

The client, an ECB-supervised bank, is required to maintain and update their Recovery Plan regularly. In this context, the client requested the assistance of Avantage Reply, to assist the bank in the production of its Group Recovery Plan.

CUSTOMER GOALS

The project aimed at achieving the following objectives:

• Draft a strawman Group Recovery Plan (GRP) document aligned with the European Central Bank’s (ECB) regulatory expectations;
• Review and update the key elements to include in its GRP (e.g. key risk indicators, stress scenarios, recovery options in normal and stressed situations, communication plan…);
• Review and update its GRP by considering Internal Audit and SREP regulatory feedback;
• Coordinate the production of its GRP document to ensure timely internal governance review, approval and submission to the ECB.

CHALLENGES

Due to the COVID-19 crisis at the time of the engagement, the client adopted a “remote only” work structure with all its employees exclusively working from home. This fact impeded the proper coordination and engagement required between the project manager and the supporting functions.

SOLUTION

Avantage Reply provided a recovery planning expert to conduct the regulatory review and update of the plan. The expert performed the following:

• Assessed the completeness of the recovery plan
• Updated the plan (incl. the recovery indicators, stress scenarios, recovery options and communication plan);
• Integrated internal audit and the SREP comments or suggestions;
• Provided general project management services to ensure timely internal governance review, approval and submission to the ECB