AFME, the Clearing House Association and the Securities Industry and Financial Markets Association have responded to FSA’s consultation paper on recovery and resolution plans (RRPs). The associations support the home country regulator leading the coordination of resolution planning and suggest FSA organises simulations of a hypothetical cross-border institution to test how FSA would participate in foreign proceedings and how foreign regulators would participate in UK ones. They have some concerns about whether the focus of the rules is appropriate in respect of non-UK headquartered groups. They stress FSA should coordinate with other regulators and undertake a gap analysis to review the information already being requested from firms to see what additional information FSA plans to require. Their final suggestion is that measures to improve resolvability should be balanced against the need to manage the business as a going concern, so that managing a prospective failure should not be to the detriment of managing for ongoing success. (Source: AFME Response to FSA Consultation 11/16)