..."Frederic Gielen of avantage has responded to the FSA's Consultation Paper CP11/9 which implements aspects of CRD 3 in the UK.  avantage's response refers to the FSA's adoption of the CEBS Guidelines for managing Operational Risk in market related activities and provides observations about the proposals and their impact on firms based on our extensive experience and practice in this area.

The full text of our response can be viewed at here

Any questions or comments about this document shold be directed to Frederic Gielen at Frederic.Gielen@avantage.eu.com"...