In our response we acknowledge FMIs increasing reliance on specific third-party services for critical business operations and proposals' alignment with the regulator's primary goal of contributing to the long-term system-wide resilience of the financial sector. However, we have cautioned them to 1) use their identification and designation of CTPs criteria judiciously as this might result in an influx of CTPs; 2) exercising careful consideration when collecting information from CTPs about FMIs as this may involve sharing sensitive information; 3) we have sought clarification on terms such as "nth party" and including the definition of operational resilience.
Other than these we have emphasised on implementing measures aimed at elucidating the implications of designation status and considering clear guidance regarding the information to be obtained from fourth-party entities.