For the FGDR, regularly testing the full operational capability of every component of its crisis management processes, particularly in terms of compensation, is essential: upstream with credit institutions and downstream with external service providers involved in the process. The FGDR, like all its foreign counterparts, finds that each test offers many useful lessons.
Along the same lines, the FGDR, together with its Supervisory Board and auditors, endeavours to fine-tune its internal control mechanisms and procedures through improvements that ensure a more precise and more qualitative understanding of risks.
Multi-year crisis preparedness programme
Since 2015, the FGDR has developed and implemented a multi-year crisis exercise programme. Each year, a growing number of elements are gradually added to this plan, which goes beyond the scope of the European guidelines, to verify the operational efficiency of the intervention mechanisms: expansion of the call centre, simulations for processing operators, operational capacity of printing, digitisation and IT service providers, responsiveness of crisis communication and liquidity of the portfolios.
The FGDR is gradually stepping up the pace of its crisis preparedness programme and increasing its requirements – to levels that even exceed the obligations set out in the European regulations – as well as mobilising the entire ecosystem of external service providers, now fully developed.
The test plan consists of two main categories: tests with credit institutions and tests with all the FGDR's partners.
Tests with banks:
More than 200
institutions tested each year
“Single Customer Views” tested each year
sixth annual regular control campaign
“Satisfactory controls” in 2020
Tests conducted with credit institutions
There are two types of tests:
- Regular controls: the aim is to ensure that each institution meets the FGDR's regulatory requirements in terms of the Single Customer View (SCV) file, the final Deposit Account Statements (DAS) and the institution's communication systems.
- Failure simulations: the goal here is to exchange information with various volunteer banks about the compensation security protocols to be implemented in the event of a failure (closing of customer transaction channels, crisis communication, generation of the SCV file and production of the DAS).
Tests conducted with the FGDR's internal players, partners and service providers
These tests cover six different areas:
- Operational tests with service providers: the aim is to monitor the systems and ensure that the service and the procedure that the service provider must follow in the compensation process are as expected.
- Dimensioning tests: their purpose is to measure the partners’ ability to determine the size of the system according to the contractual conditions. The development of these tests is based on a large failed institution.
- “Total Flow” tests: the objective is to verify the ability of the FGDR’s system to handle all the situations resulting from a compensation process. The compensation system is implemented in its entirety (all activities, all stakeholders, all organisations, all tools).
- Area-specific simulations: a specific part of the compensation system is stressed in order to fully assess its operability, efficiency, robustness or security.
- Intrusion tests: here the resistance of the computer systems (institutional website, CCS, contribution management platform, office equipment) to malicious attacks is tested.
- Cross-border tests: the goal here is to verify, in the event of the failure of an institution with branches in the European Union, the operability of exchanges between the FGDR and its counterpart in the country where the branch is located so as to compensate the branch's depositors successfully via the local scheme.