Cloud Computing in the Financial Sector: A Global Perspective

Program on International Financial Systems 2019

41 Pages Posted: 30 Jul 2019

See all articles by Hal S. Scott

Hal S. Scott

Harvard Law School

John Gulliver

Program on International Financial Systems

Hillel Nadler

Wayne State University Law School

Date Written: July 26, 2019

Abstract

As financial institutions move their operations, including core functions, to the cloud, financial regulators have begun to issue regulations and informal guidance addressing the use of cloud services in the financial sector. These are typically based on the regulator’s existing framework for outsourcing by a financial institution to third-party technology providers, under which the risks associated with outsourcing and the supervision of third-party providers are primarily the responsibility of the financial institution. This report provides background on the use of cloud computing in the financial sector, reviews existing regulatory and supervisory frameworks for cloud use by financial institutions, and recommends improvements to those frameworks that could reduce obstacles to more widespread cloud adoption by financial institutions.

Keywords: cloud computing, third-party service providers, technology infrastructure, financial system

Suggested Citation

Scott, Hal S. and Gulliver, John and Nadler, Hillel, Cloud Computing in the Financial Sector: A Global Perspective (July 26, 2019). Program on International Financial Systems 2019, Available at SSRN: https://ssrn.com/abstract=3427220

Hal S. Scott (Contact Author)

Harvard Law School ( email )

1557 Massachusetts Avenue
Cambridge, MA 02138
United States
617-495-4590 (Phone)
617-495-9593 (Fax)

John Gulliver

Program on International Financial Systems ( email )

134 Mt Auburn St.
Cambridge, MA 02138
United States
02138 (Fax)

Hillel Nadler

Wayne State University Law School ( email )

471 Palmer
Detroit, MI 48202
United States

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