On July 2014, the FCA published a document setting out considerations (including guideline questions) for firms thinking about using third-party technology (off-the-shelf) banking solutions. Where the services offered are critical to a regulated firm’s business operations, the service providers are regarded by the FCA as outsource service providers and the regulated firm is then subject to regulatory obligations designed to manage operational risk.

The document is available at:

http://www.fca.org.uk/your-fca/documents/considerations-for-firms-thinking-of- using-third-party-technology-banking-solutions.