The Bank for International Settlements (BIS) issued two consultation documents in August for comment by November 6:

• Revisions to the principles for the sound management of operational risk
• Principles for operational resilience

For operational resiliency, Capco’s perspective is BIS is headed in the wrong direction and has set a bar that is too low to drive real change. In this paper, we have listed ten reasons why Capco believes the BIS consultation paper is flawed by setting both a low bar for compliance and is heading in the wrong direction without giving role clarity.