2. Feedback to responses
2.1 The PRA must consider representations that are made to it in accordance with its duty to consult on its general policies and practices and must publish, in such manner as it thinks fit, responses to the representations.
2.2 The PRA has considered the responses received to the CP. This chapter sets out the PRA's feedback to those responses, and its final decisions.
2.3 Respondents provided thematic feedback on the proposals as well as feedback on the individual principles and sub-principles. Respondents requested clarification of certain aspects of the principles which are summarised in this chapter. The sections of this chapter have been structured as follows:
- feedback where changes have been made to draft policy
- feedback on MRM for AI/ML models
- additional feedback received
Feedback where changes have been made to draft policy
Senior Management Function (SMF) accountability
2.4 Respondents welcomed the proposed introduction of an accountable individual for the MRM framework and agreed that the Chief Risk Function (SMF4) is likely to be the most appropriate individual to fulfil this proposed expectation. Respondents raised concerns, however, that the proposed responsibilities were too prescriptive for an SMF holder. Respondents also sought clarity over the ambiguity in the references to the SMF's accountability that appear to encompass both the second and first line of defence responsibilities.