3 minute read 5 Sep 2019
Dress rehearsals for Brexit

5 priority actions for a successful Brexit dress rehearsal

By

EY FS Insights

Minds Made for Financial Services

3 minute read 5 Sep 2019

With less than two months before the UK is due to leave the EU, what actions do firms need to consider to run a successful dress rehearsal ahead of the Brexit deadline?

With the new UK Prime Minister’s resolve to leave the EU by 31 October 2019, the likelihood of a no-deal Brexit scenario has significantly increased. Most of the financial services (FS) industry had prepared for a potential no-deal Brexit in March and since then we have seen firms take different approaches to the Article 50 extension. Some firms continued to execute their Brexit programs as planned, others used the additional time to revisit some of their decisions made in the lead up to 29 March. There were also those who slowed down their programmes whilst they waited for further clarity from the political process.

Many FS institutions have set up a European entity in readiness to onboard and trade with clients. Despite the efforts to centralise processes and migrate clients to this entity, some clients have been unwilling to agree to an early migration and wish to wait until the last possible moment. For banks, in particular, this has resulted in adoption of a dual operating model which, whilst creating a mechanism to continue trading with clients across both the UK and EU27, adds further complexity and necessitates a dress rehearsal at the point when the UK becomes a third country. Banks should be evaluating and testing the changes to their front-office control frameworks at this point to mitigate the risk of unauthorized trading on 1 November and ensure provision of the best outcomes for clients planning to migrate to their new European entity. Insurers, on the other hand, have used Part VII transfers to complete their client migration activity between the UK and EU27 entities, and therefore do not face a similar challenge. 

Regardless of the approach taken during the extension, firms need to be prepared for the probability of a no-deal Brexit and plan to perform at least one dress rehearsal of the Brexit event ahead of 31 October. The dress rehearsal should aim to prove that all technology, operational processes and migrations will support the overnight transition from the UK being an EU Member State to becoming a third country.

The dress rehearsal should also consider the impact on processes of plausible scenarios that may impact the cut-over event – for instance disruption to transport because of protests or significant market volatility. Stress testing of these scenarios will help confirm that firms’ plans, management teams and decision-making processes are sufficiently robust and resilient to handle what may be an uncertain period.

Another factor that should be considered is contention with other processes that may be occurring at the same time, for example finance month end. Changes to systems may impact month end processes as well as subsequent financial and regulatory reporting. In addition, the capacity of a finance function may be strained by the requirement to support the go-live activities.

Typically, go-live events are planned on weekends to reduce the risk of disruption to the business. Whilst this would have been the case for both 29 March and 12 April dates, the current Brexit date is midweek. This may represent a challenge of ensuring all migration activities are completed within a shorter timeframe than was previously available. This will be of particular significance to global organisations with presence in the US and Asia-Pacific given the potential impact during trading hours in those regions. Therefore, previous Brexit plans will have to be reviewed with this challenge in mind and updated as appropriate. 

Given all these factors, there is a clear need for firms to review their current go-live plans, undertake a thorough risk assessment and devise appropriate mitigation and contingency strategies. In order to run a successful dress rehearsal, firms should consider and perform the following five key activities (see Figure 1): 

  1. Planning: Document every step of the cut over, highlighting technical and business requirements that need to be met for operational readiness post 31 October
  2. Governance: Define the dress rehearsal governance framework outlining key roles and responsibilities as well as reporting lines during the dress rehearsal planning and execution 
  3. Communication: Outline a plan for internal communication, including key dress rehearsal information and procedures for distribution to internal stakeholders
  4. Escalation procedures: Define a clear process for escalating risks and issues during the dress rehearsal planning and execution  
  5. Reporting: Document the lessons learnt and act on the findings immediately following a dress rehearsal 

Typically, around 4 to 6 weeks are needed to fully plan and execute such an exercise, and in the context of the current timeline firms should run a dress rehearsal by mid-October allowing sufficient time to remediate issues which may arise. Specifically, this activity should involve broad stakeholder representation covering front-office, operations, technology, finance and risk to allow thorough review of the plan and cross-functional agreement to mitigating actions for any risks identified.

Whilst the new Brexit deadline of 31 October presents challenges, these can be addressed with the appropriate planning. It is essential that firms start preparing now and schedule at least one dress rehearsal of all business and technology activities taking place on and immediately after 31 October.

Summary

With the UK Prime Minister’s resolve to leave the EU by 31 October 2019, the likelihood of a no-deal Brexit scenario has significantly increased. Most of the financial services industry had prepared for a potential no-deal Brexit in March and since then we have seen firms take different approaches to the Article 50 extension. Some firms continued to execute their Brexit programs as planned, others used the additional time to revisit their decisions made in the lead up to 29 March. There were also those who slowed down their programmes whilst they waited for further clarity from the political process.

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By

EY FS Insights

Minds Made for Financial Services