Capital

Part

BIPRU Prudential sourcebook for Banks, Building Societies and Investment Firms

Chapter

Capital

Printed on: 01/11/2024

Rulebook at: 31/12/2010

BIPRU 2

Capital

BIPRU 2.1

Solo consolidation

01/01/2007

Application

BIPRU 2.1.1

This section applies to a BIPRU firm that has a solo consolidation waiver.

01/01/2007

Purpose

BIPRU 2.1.2

The purpose of this section is to implement Articles 70 and 118 of the Banking Consolidation Directive. It also implements Articles 2 and 28 of the Capital Adequacy Directive so far as they apply those provisions of the Banking Consolidation Directive to CAD investment firms.

01/01/2007

BIPRU 2.1.3

The rules in GENPRU and BIPRU do not allow a firm that is a parent undertaking to incorporate the capital and requirements of a subsidiary undertaking in the calculation of that firm's capital resources and capital resources requirement. A firm that wishes to incorporate a subsidiary undertaking for this purpose should therefore apply for a solo consolidation waiver.

01/01/2007

Applying for a solo consolidation waiver

BIPRU 2.1.4

BIPRU 1.3 (Applications for advanced approaches) explains how to apply for a solo consolidation waiver.

01/01/2007

General

BIPRU 2.1.5

The FSA will not grant a firm a solo consolidation waiver with respect to a subsidiary undertaking unless the firm and the subsidiary undertaking meet the standards in BIPRU 2.1.19 R to BIPRU 2.1.24 R.

01/01/2007

BIPRU 2.1.6

A solo consolidation waiver will modify the relevant parts of GENPRU, BIPRU and SYSC referred to in BIPRU 2.1.7 R to BIPRU 2.1.8 R to apply BIPRU 2.1 to a firm.

01/01/2007

The basic rules for solo consolidation

BIPRU 2.1.7

A firm that has a solo consolidation waiver must incorporate in the calculation of its requirements under the main BIPRU firm Pillar 1 rules and BIPRU 10 (Large exposure requirements) each subsidiary undertaking to which the solo consolidation waiver applies. This does not apply to the base capital resources requirement.

31/12/2010

BIPRU 2.1.8

(1) A firm that has a solo consolidation waiver must meet the obligations in SYSC 12.1.13 R (Application of certain systems and controls rules on a consolidated basis) on a consolidated basis with respect to the firm and each subsidiary undertaking to which the firm's solo consolidation waiver applies.
(2) If (1) applies, SYSC 12.1.13 R applies to the group made up of the firm and its subsidiary undertakings referred to in (1) in the same way as it applies to a UK consolidation group or non-EEA sub-group.
(3) If (1) applies, the provisions of SYSC and BIPRU listed in SYSC 12.1.13 R do not apply to the firm on a solo basis.

01/01/2007

Solo consolidation and capital and concentration risk requirements

BIPRU 2.1.9

BIPRU 2.1.10 R to BIPRU 2.1.18 R apply for the purposes of BIPRU 2.1.7 R.

01/01/2007

BIPRU 2.1.10

A firm must treat itself and each subsidiary undertaking referred to in BIPRU 2.1.7 R as a single undertaking and must apply, on that basis, BIPRU 8 (Group risk - consolidation) to the group made up of the firm and such subsidiary undertakings in the same way as BIPRU 8 applies to a UK consolidation group or non-EEA sub-group.

01/01/2007

BIPRU 2.1.11

Subject to BIPRU 2.1.13 R, a firm must calculate its capital resources in accordance with BIPRU 8.6 (Consolidated capital resources).

01/01/2007

BIPRU 2.1.12

A firm must calculate its capital resources requirement in accordance with BIPRU 8.7.13 R (3) (Treating group members as a single undertaking for consolidation purposes).

01/01/2007

BIPRU 2.1.13

Where GENPRU applies a different method of calculating capital resources or capital resources requirements depending on the category into which the firm in question falls, the method that applies is the one that would apply to the firm on a solo basis.

01/01/2007

BIPRU 2.1.14

For example, the effect of BIPRU 2.1.13 R is that if a firm that is applying BIPRU 2.1 is a limited licence firm it should continue to apply the capital resources and capital resources requirement applicable to a limited licence firm.

01/01/2007

BIPRU 2.1.15

A firm must continue to calculate its base capital resources requirement and the requirement in GENPRU 2.1.42 R (Calculation of capital resources requirement on authorisation) on a solo basis.

01/01/2007

BIPRU 2.1.16

A firm must apply BIPRU 10 (Large exposure requirements) in accordance with BIPRU 8.9A (Consolidated large exposures requirements). Accordingly the firm must apply BIPRU 8.9A to the group made up of the firm and the subsidiary undertakings referred to in BIPRU 2.1.7 R in the same way as BIPRU 8.9A applies to a UK consolidation group or non-EEA sub-group.

31/12/2010

BIPRU 2.1.17

One effect of BIPRU 2.1.16 R is that BIPRU 10.8A (Core UK groups) and BIPRU 10.9A (Non-core large exposures groups) do not apply. The corresponding provisions of BIPRU 8.9A (Consolidated large exposures requirements) apply instead.

31/12/2010

BIPRU 2.1.18

A firm must include in full any subsidiary undertaking in respect of which the firm applies BIPRU 2.1 in the calculations under BIPRU 2.1.7 R.

01/01/2007

Minimum standards

BIPRU 2.1.19

A firm must not apply BIPRU 2.1 to a subsidiary undertaking to which the firm's solo consolidation waiver applies BIPRU 2.1 unless in addition it meets the conditions in BIPRU 2.1.20 R to BIPRU 2.1.24 R.

01/01/2007

BIPRU 2.1.20

The risk evaluation, measurement and control procedures of the firm must cover the subsidiary undertaking referred to in BIPRU 2.1.19 R.

01/01/2007

BIPRU 2.1.21

The firm must hold more than 75% of the voting rights attaching to the shares in the capital of the subsidiary undertaking referred to in BIPRU 2.1.19 R and must have the right to appoint or remove a majority of the members of the governing body of the subsidiary undertaking.

01/01/2007

BIPRU 2.1.22

The material exposures or material liabilities of the subsidiary undertaking referred to in BIPRU 2.1.19 R must be to the firm.

01/01/2007

BIPRU 2.1.23

Where the firm is a parent institution in a Member State, it must have measures in place that ensure the satisfactory allocation of risks within the group consisting of the firm and each subsidiary undertaking to which BIPRU 2.1 is applied.

01/01/2007

BIPRU 2.1.24

A firm must be able to demonstrate fully to the FSA the circumstances and arrangements, including legal arrangements, by virtue of which there are no material practical or legal impediments, and none are foreseen, to the prompt transfer of the capital resources of the subsidiary undertaking referred to in BIPRU 2.1.19 R or repayment of liabilities when due by the subsidiary undertaking to the firm.

01/01/2007

BIPRU 2.1.25

The following are the criteria that the FSA will take into account when considering whether the condition in BIPRU 2.1.24 R is going to be met:

(1) the speed with which funds can be transferred or liabilities repaid to the firm and the simplicity of the method for the transfer or repayment;
(2) whether there are any interests other than those of the firm in the subsidiary undertaking and what impact those other interests may have on the firm's control over the subsidiary undertaking and on the ability of the firm to require a transfer of funds or repayment of liabilities;
(3) whether the prompt transfer of funds or repayment of liabilities to the firm might harm the reputation of the firm or its subsidiary undertakings;
(4) whether there are any tax disadvantages for the firm or the subsidiary undertaking as a result of the transfer of funds or repayment of liabilities;
(5) whether there are any exchange controls that may have an impact on the transfer of funds or repayment of liabilities;
(6) whether there are assets in the subsidiary undertaking available either to be transferred or liquidated for the purposes of the transfer of funds or repayment of liabilities;
(7) whether any regulatory requirements impact on the ability of the subsidiary undertaking to transfer funds or repay liabilities promptly;
(8) whether the purpose of the subsidiary undertaking prejudices the prompt transfer of funds or repayment of liabilities;
(9) whether the legal structure of the subsidiary undertaking prejudices the prompt transfer of funds or repayment of liabilities;
(10) whether the contractual relationships of the subsidiary undertaking with the firm and other third parties prejudices the prompt transfer of funds or repayment of liabilities;
(11) whether past and proposed flows of funds between the subsidiary undertaking and the firm demonstrate the ability to make prompt transfer of funds or repayment of liabilities; and
(12) whether the degree of solo consolidation by the firm undermines the FSA's ability to assess the soundness of the firm as a legal entity (taking into account any other subsidiary undertakings to which BIPRU 2.1 is being applied).

01/01/2007

BIPRU 2.1.26

The effect of BIPRU 2.1.19 R is that even though a firm's solo consolidation waiver applies BIPRU 2.1 with respect to a subsidiary undertaking, the firm should not apply BIPRU 2.1 with respect to that subsidiary undertaking unless in addition it meets the conditions in BIPRU 2.1.20 R to BIPRU 2.1.24 R.

01/01/2007

BIPRU 2.1.27

A firm should not apply BIPRU 2.1 to a subsidiary undertaking to which the firm's solo consolidation waiver applies if it ceases to be a subsidiary undertaking of the firm even if the solo consolidation waiver is not varied by removing the subsidiary undertaking.

01/01/2007

BIPRU 2.1.28

If a subsidiary undertaking referred to in BIPRU 2.1.27 G later becomes a subsidiary undertaking again the firm should not apply BIPRU 2.1 to it unless the solo consolidation waiver is varied to re-apply it with respect to the subsidiary undertaking.

01/01/2007

BIPRU 2.2

Internal capital adequacy standards

01/01/2007

Application

BIPRU 2.2.1

BIPRU 2.2 applies to a BIPRU firm.

01/01/2007

Purpose

BIPRU 2.2.2

(1) BIPRU 2.2 sets out guidance on GENPRU 1.2 (Adequacy of financial resources) so far as it applies to a BIPRU firm. In particular it sets out guidance on how a firm should carry out its ICAAP, as well as some factors the FSA will take into consideration when undertaking a SREP. The terms ICAAP and SREP are explained in BIPRU 2.2.4 G. BIPRU 2.2.41 R-BIPRU 2.2.43 R are rules that apply to a firm with an IRB permission.
(2) BIPRU 2.2 is for the most part written on the basis that GENPRU 1.2 (Adequacy of financial resources) applies to a firm on a solo basis. However it is still relevant when GENPRU 1.2 applies on a consolidated basis. When GENPRU 1.2 applies on a consolidated basis, BIPRU 2.2 should be read with appropriate adjustments.

01/01/2007

Meaning of capital

BIPRU 2.2.3

For the purpose of BIPRU 2.2, "capital" refers to a firm's financial resources, capital resources and internal capital, all as referred to in the overall Pillar 2 rule.

01/01/2007

The ICAAP and the SREP: Introduction

BIPRU 2.2.4

The adequacy of a firm's capital needs to be assessed both by a firm and the FSA. This process involves:

(1) an internal capital adequacy assessment process (ICAAP), which a firm is obliged to carry out in accordance with the ICAAP rules; and
(2) a supervisory review and evaluation process (SREP), which is conducted by the FSA.

01/01/2007

The ICAAP and the SREP: The ICAAP

BIPRU 2.2.5

The obligation to conduct an ICAAP, includes requirements on a firm to:

(1) carry out regularly assessments of the amounts, types and distribution of financial resources, capital resources and internal capital that it considers adequate to cover the nature and level of the risks to which it is or might be exposed (GENPRU 1.2.30 R to GENPRU 1.2.41 G (the overall Pillar 2 rule and related rules);
(2) identify the major sources of risk to its ability to meet its liabilities as they fall due (the overall Pillar 2 rule);
(3) conduct stress and scenario tests (the general stress and scenario testing rule), taking into account, in the case of a firm with an IRB permission, the stress test required by BIPRU 4.3.39 R to BIPRU 4.3.40 R (Stress tests used in assessment of capital adequacy for a firm with an IRB permission);
(4) ensure that the processes, strategies and systems required by the overall Pillar 2 rule and used in its ICAAP, are both comprehensive and proportionate to the nature, scale and complexity of that firm's activities (GENPRU 1.2.35 R); and
(5) document its ICAAP (GENPRU 1.2.60 R).

01/01/2007

BIPRU 2.2.6

Where a firm is a member of a group, it should base its ICAAP on the consolidated financial position of the group. The group assessment should include information on diversification benefits and transferability of resources between members of the group and an apportionment of the capital required by the group as a whole to the firm (GENPRU 1.2.44 G to GENPRU 1.2.56 G (Application of GENPRU 1.2 on a solo and consolidated basis: Processes and tests)). A firm may, instead of preparing the ICAAP itself, adopt as its ICAAP an assessment prepared by other group members.

01/01/2007

BIPRU 2.2.7

A firm should ensure that its ICAAP is:

(1) the responsibility of the firm's governing body;
(2) reported to the firm's governing body; and
(3) forms an integral part of the firm's management process and decision-making culture.

01/01/2007

The ICAAP and the SREP: The SREP

BIPRU 2.2.8

The FSA will review a firm's ICAAP, including the results of the firm's stress tests carried out under GENPRU and BIPRU, as part of its SREP. Provided that the FSA is satisfied with the appropriateness of a firm's capital assessment, the FSA will take into account that firm's ICAAP and stress tests in its SREP. More material on stress tests for a firm with an IRB permission can be found in BIPRU 2.2.41 R to BIPRU 2.2.45 G.

24/09/2010

BIPRU 2.2.9

The SREP is a process under which the FSA:

(1) reviews the arrangements, strategies, processes and mechanisms implemented by a firm to comply with GENPRU, BIPRU and SYSC and with requirements imposed by or under the regulatory system and evaluates the risks to which the firm is or might be exposed;
(2) determines whether the arrangements, strategies, processes and mechanisms implemented by the firm and the capital held by the firm ensures a sound management and coverage of the risks in (1); and
(3) (if necessary) requires the firm to take the necessary actions or steps at an early stage to address any failure to meet the requirements referred to in (1).

01/01/2007

BIPRU 2.2.10

As part of its SREP, the FSA may ask a firm to provide it with the results of that firm's ICAAP, together with an explanation of the process used. Where appropriate, the FSA will ask for additional information on the ICAAP.

01/01/2007

BIPRU 2.2.11

As part of its SREP, the FSA will consider whether the amount and quality of capital which a firm should hold to meet its CRR in GENPRU 2.1 (Calculation of capital resources requirements) is sufficient for that firm to comply with the overall financial adequacy rule.

24/09/2010

BIPRU 2.2.12

After completing a review as part of the SREP, the FSA will normally give that firm individual guidance (individual capital guidance), advising it of the amount and quality of capital which it should hold to meet the overall financial adequacy rule.

24/09/2010

BIPRU 2.2.12A

As part of its SREP, the FSA will also consider whether a firm should hold a capital planning buffer and, in that case, the amount and quality of such capital planning buffer. In making these assessments, the FSA will have regard to the nature, scale and complexity of a firm's business and of the major sources of risks relevant to such business as referred to in the general stress and scenario testing rule. Accordingly, a firm's capital planning buffer should be of sufficient amount and adequate quality to allow the firm to continue to meet the overall financial adequacy rule in the face of adverse circumstances, after allowing for realistic management actions.

24/09/2010

BIPRU 2.2.12B

After completing a review as part of the SREP, the FSA may notify the firm of the amount and quality of capital which it should hold as a capital planning buffer over and above the level of capital recommended as its ICG. The FSA may set a firm's capital planning buffer either as an amount and quality of capital which it should hold now (that is, at the time of the FSA's notification following the firm's SREP) or, in exceptional cases, as a forward looking target that the firm should build up over time.

24/09/2010

BIPRU 2.2.12C

Where the amount or quality of capital which the FSA considers a firm should hold to meet the overall financial adequacy rule or as a capital planning buffer is not the same as that which results from a firm's ICAAP, the FSA usually expects to discuss any such difference with the firm. Where necessary, the FSA may consider the use of its powers under section 166 of the Act (Reports by skilled persons) to assist in such circumstances.

24/09/2010

BIPRU 2.2.13

If a firm considers that the individual capital guidance given to it is inappropriate to its circumstances it should, consistent with Principle 11 (Relations with regulators), inform the FSA that it disagrees with that guidance. The FSA may reissue individual capital guidance if, after discussion with the firm, the FSA concludes that the amount or quality of capital that the firm should hold to meet the overall financial adequacy rule is different from the amount or quality initially suggested by the FSA.

24/09/2010

BIPRU 2.2.13A

If a firm disagrees with the FSA's assessment as to the amount or quality of capital planning buffer that it should hold, it should, consistent with Principle 11 (Relations with regulators), notify the FSA of its disagreement. The FSA may reconsider its initial assessment if, after discussion with the firm, the FSA concludes that the amount or quality of capital that the firm should hold as capital planning buffer is different from the amount or quality initially suggested.

24/09/2010

BIPRU 2.2.14

The FSA will not give individual capital guidance to the effect that the amount of capital advised in that guidance is lower than the amount of capital which a firm should hold to meet its CRR.

01/01/2007

BIPRU 2.2.15

If, after discussion, the FSA and a firm still do not agree on an adequate level of capital, the FSA may consider using its powers under section 45 of the Act to vary on its own initiative a firm's Part IV permission so as to require it to hold capital in accordance with the FSA's view of the capital necessary to comply with the overall financial adequacy rule. In deciding whether it should use its powers under section 45, the FSA will take into account the amount and quality of the capital planning buffer which the firm should hold as referred to in BIPRU 2.2.12A G and BIPRU 2.2.12B G. SUP 7 provides further information about the FSA's powers under section 45.

24/09/2010

The drafting of individual capital guidance and capital planning buffer

BIPRU 2.2.16

If the FSA gives individual capital guidance to a firm, the FSA will state what amount and quality of capital the FSA considers the firm needs to hold in order to comply with the overall financial adequacy rule. It will generally do so by saying that the firm should hold capital resources of an amount which is at least equal to a specified percentage of that firm's capital resources requirement plus one or more static add-ons in relation to specific risks in accordance with the overall Pillar 2 rule.

24/09/2010

BIPRU 2.2.17

(1) Individual capital guidance may refer to two types of capital resources.
(2) The first type is referred to as general capital. It refers to total tier one capital resources and tier two capital resources after deductions.
(3) The second type is referred to as total capital. It refers to total tier one capital resources, tier two capital resources and tier three capital resources after deductions.

01/01/2007

BIPRU 2.2.18

(1) In both of the cases in BIPRU 2.2.17 G capital resources should be calculated in the same way as they are in GENPRU 2.2 (Capital resources). This includes the rules limiting the amount of capital that can be included in the various tiers of capital when capital resources are being calculated.
(2) GENPRU 2.2.42 R does not allow innovative tier one capital to count as tier one capital resources for certain purposes. This restriction does not apply for the purposes in BIPRU 2.2.17 G.

01/01/2007

BIPRU 2.2.19

(1) Individual capital guidance may also be given with respect to group capital resources. This paragraph explains how such guidance should be interpreted unless the individual capital guidance specifies another interpretation.
(2) If BIPRU 8.2.1 R (General consolidation rule for a UK consolidation group) applies to the firm the guidance relates to its UK consolidation group. If BIPRU 8.3.1 R (General consolidation rule for a non-EEA sub-group) applies to the firm the guidance relates to its non-EEA sub-group. If both apply to the firm the guidance relates to its UK consolidation group and to its non-EEA sub-group.
(3) The guidance will be on the overall financial adequacy rule as it applies on a consolidated basis under GENPRU 1.2.59 R (Application of GENPRU 1.2 on a solo and consolidated basis: Adequacy of resources) and insofar as it refers to capital resources.
(4) BIPRU 2.2.16 G to BIPRU 2.2.18 G apply for the purpose of this paragraph as they apply to guidance given on a solo basis. References to capital resources should be read as being to consolidated capital resources.

01/01/2007

BIPRU 2.2.19A

Where the FSA notifies a firm that it should hold a capital planning buffer, the notification will state what amount and quality of capital the FSA considers that is adequate for the firm to hold as such. This will normally be notified to the firm together with its individual capital guidance and expressed as a separate amount of capital resources that the firm should hold in excess of the amount of capital resources indicated as its individual capital guidance.

24/09/2010

BIPRU 2.2.19B

For the purposes of BIPRU 2.2.19A G, BIPRU 2.2.17 G to BIPRU 2.2.19 G apply as they apply to individual capital guidance. References in those provisions to individual capital guidance or guidance should be read as if they were references to capital planning buffer. In relation to BIPRU 2.2.19G (3) and GENPRU 1.2.59 R, where the general stress and scenario testing rule, as part of the ICAAP rules, applies to a firm on a consolidated basis, the FSA may notify the firm that it should hold a group capital planning buffer. In these cases, the firm should ensure that the group holds a capital planning buffer of sufficient amount and adequate quality to allow it to continue to meet the overall financial adequacy rule in the face of adverse circumstances, after allowing for realistic management actions.

24/09/2010

Failure to meet individual capital guidance and monitoring and reporting on the capital planning buffer

BIPRU 2.2.20

A firm's continuing to hold capital in accordance with its individual capital guidance and its ability to carry on doing so is a fundamental part of the FSA's supervision of that firm. Therefore if a firm's capital resources have fallen, or are expected to fall, below the level advised in individual capital guidance, then, consistent with Principle 11 (Relations with regulators), a firm should inform the FSA of this fact as soon as practicable, explaining why this has happened or is expected to happen and:

(1) what action the firm intends to take to increase its capital resources or to reduce its risks and hence its capital requirements; or
(2) what modification the firm considers should be made to the individual capital guidance which it has been given.

01/01/2007

BIPRU 2.2.21

In the circumstance set out in BIPRU 2.2.20 G, the FSA may ask a firm for alternative or more detailed proposals and plans or further assessments and analyses of capital adequacy and risks faced by the firm. The FSA will seek to agree with the firm appropriate timescales and scope for any such additional work, in light of the circumstances which have arisen.

01/01/2007

BIPRU 2.2.22

If a firm has not accepted individual capital guidance given by the FSA it should, nevertheless, inform the FSA as soon as practicable if its capital resources have fallen, or are expected to fall, below the level suggested by that individual capital guidance.

01/01/2007

BIPRU 2.2.23

Monitoring the use of a firm's capital planning buffer is also a fundamental part of the FSA's supervision of that firm. A firm should only use its capital planning buffer to absorb losses or meet increased capital requirements if certain adverse circumstances materialise. These should be circumstances beyond the firm's normal and direct control, whether relating to a deteriorating external environment or periods of stress such as macroeconomic downturns or financial/market shocks, or firm-specific circumstances.

24/09/2010

BIPRU 2.2.23A

Consistent with Principle 11 (Relations with regulators), a firm should notify the FSA as early as possible in advance where it has identified that it would need to use its capital planning buffer. The firm's notification should at least state:

(1) what adverse circumstances are likely to force the firm to draw down its capital planning buffer;
(2) how the capital planning buffer will be used up in line with the firm's capital planning projections; and
(3) what plan is in place for the eventual restoration of the capital planning buffer.

24/09/2010

BIPRU 2.2.23B

Following discussions with the firm on the items listed in BIPRU 2.2.23AG (1) to BIPRU 2.2.23AG (3), the FSA may put in place additional reporting arrangements to monitor the firm's use of its capital planning buffer in accordance with the plan referred to in BIPRU 2.2.23AG (3). The FSA may also identify specific trigger points as the capital planning buffer is being used up by the firm, which could lead to additional supervisory actions.

24/09/2010

BIPRU 2.2.23C

Where a firm's capital planning buffer is being drawn down due to circumstances other than those referred to in BIPRU 2.2.23 G, such as poor planning or mismanagement, the FSA may ask the firm for more detailed plans for it to restore its capital planning buffer. In the light of the relevant circumstances, the FSA may consider taking other remedial actions, which may include using its powers under section 45 of the Act to vary on its own initiative a firm's Part IV permission.

24/09/2010

BIPRU 2.2.23D

A firm should inform the FSA where its capital planning buffer is likely to start being drawn down even if it has not accepted the FSA's assessment as to the amount or quality of its capital planning buffer.

24/09/2010

BIPRU 2.2.23E

Where a firm has started to use its capital planning buffer in circumstances where it was not possible to notify in advance, it should notify the FSA and provide the information referred to in BIPRU 2.2.23A G as soon as practicable afterwards.

24/09/2010

BIPRU 2.2.23F

BIPRU 2.2.20 G to BIPRU 2.2.23E G also apply to individual capital guidance and to capital planning buffer on a consolidated basis as referred to in BIPRU 2.2.19 G.

24/09/2010

Proportionality of an ICAAP

BIPRU 2.2.24

BIPRU 2.2.25 G to BIPRU 2.2.27 G set out what the FSA considers to be a proportional approach to preparing an ICAAP as referred to in GENPRU 1.2.35 R (The processes, strategies and systems required by the overall Pillar 2 rule should be comprehensive and proportionate), according to the relative degree of complexity of a firm's activities. If a firm adopts the appropriate approach, it may enable the FSA more easily to review a firm's ICAAP when the FSA undertakes its SREP. The FSA is also likely to place more reliance on an ICAAP which takes the appropriate form described in BIPRU 2.2.25 G to BIPRU 2.2.27 G than would otherwise be the case although there may also be circumstances in which the FSA will be able to rely on an ICAAP that is not drawn up in that form.

01/01/2007

BIPRU 2.2.25

(1) This paragraph applies to a small firm whose activities are simple and primarily not credit-related.
(2) In carrying out its ICAAP it could:

(a) identify and consider that firm's largest losses over the last 3 to 5 years and whether those losses are likely to recur;
(b) prepare a short list of the most significant risks to which that firm is exposed;
(c) consider how that firm would act, and the amount of capital that would be absorbed, in the event that each of the risks identified were to materialise;
(d) consider how that firm's CRR might alter under the scenarios in (c) and how its CRR might alter in line with its business plans for the next 3 to 5 years;
(e) consider whether any of the risks in the overall Pillar 2 rule is applicable to the firm (it is unlikely that any of those risks not already identified in (a) or (b) will apply to a firm whose activities are simple);
(f) document the ranges of capital required in the scenarios identified and form an overall view on the amount and quality of capital which that firm should hold, ensuring that its senior management is involved in arriving at that view; and
(g) (in order to determine the amount of capital that would be absorbed in the circumstances detailed in (c)) carry out simple sensitivity tests where the firm analyses the impact of a shift in the key risk parameters identified in (b) on the earnings of the firm.

(3) A firm is also expected to form a view on the consolidated amount of capital it should hold as well as the capital required to be held in respect of each of the individual risks identified under the overall Pillar 2 rule. For that purpose, it may conservatively sum the results of the individual tests performed in (2)(c). If the firm chooses however to reduce that sum on the understanding that not all risks will materialise at the same time, then the firm should perform scenario tests that demonstrate that a reduction in capital is legitimate.
(4) A firm should conduct stress tests and scenario analyses in accordance with GENPRU 1.2.42 R to assess how that firm's capital and CRR would alter and what that firm's reaction might be to a range of adverse scenarios, including operational and market events. Where relevant, a firm should also consider the impact of a severe economic or industry downturn on its future earnings, capital resources and capital resources requirement, taking into account its business plans. The downturn scenario should be based on forward looking hypothetical events calibrated against the most adverse movements in individual risk drivers experienced over a long historical period.

14/12/2009

BIPRU 2.2.26

In relation to a firm whose activities are moderately complex, in carrying out its ICAAP, BIPRU 2.2.25 G (3) to (4) apply. In addition, it could:

(1) having consulted the management in each major business line, prepare a comprehensive list of the major risks to which the business is exposed;
(2) estimate, with the aid of historical data, where available, the range and distribution of possible losses which might arise from each of those risks and consider using shock stress tests to provide risk estimates;
(3) consider the extent to which that firm's CRR adequately captures the risks identified in (1) and (2);
(4) for areas in which the CRR is either inadequate or does not address a risk, estimate the additional capital (if any) needed to protect that firm and its customers, in addition to any other risk mitigation action that firm plans to take;
(5) consider the risk that that firm's own analyses of capital adequacy may be inaccurate and that it may suffer from management weaknesses, which affect the effectiveness of its risk management and mitigation;
(6) project that firm's business activities forward in detail for one year and in less detail for the next 3 to 5 years and estimate how that firm's capital and CRR would alter, assuming that business develops as expected;
(7) assume that business does not develop as expected and consider how that firm's capital and CRR would alter and what that firm's reaction to a range of adverse economic scenarios might be (see GENPRU 1.2.30 R to GENPRU 1.2.43 G (the overall Pillar 2 rule and related rules and guidance)). Where appropriate, the adverse scenarios should consider the impact of market events that are instantaneous or occur over an extended period of time but which are nevertheless still co-dependent on movements in economic conditions;
(8) document the results obtained from the analyses in (2), (4), (6), and (7) in a detailed report for that firm's senior management, and, where relevant, its governing body; and
(9) ensure that systems and processes are in place to review against performance the accuracy of the estimates made in (2), (4), (6) and (7).

14/12/2009

BIPRU 2.2.27

(1) This paragraph applies to a proportional ICAAP in the case of a firm whose activities are complex.
(2) A proportional approach to that firm's ICAAP should cover the matters identified in BIPRU 2.2.26 G, but is likely also to involve the use of models, most of which will be integrated into its day-to-day management and operation.
(3) Models of the sort referred to in (2) may be linked so as to generate an overall estimate of the amount of capital that a firm considers appropriate to hold for its business needs. For example, a firm is likely to use value at risk models for market risk (see BIPRU 7.10), advanced modelling approaches for credit risk (see BIPRU 4) and, possibly, advanced measurement approaches for operational risk (see BIPRU 6.5). A firm might also use economic scenario generators to model stochastically its business forecasts and risks. A firm may also link such models to generate information on the economic capital desirable for that firm. A model which a firm uses to generate its target amount of economic capital is known as an economic capital model (ECM). Economic capital is the target amount of capital which maximises the return for a firm's stakeholders for a desired level of risk.
(4) A firm is also likely to be part of a group and to be operating internationally. There is likely to be centralised control over the models used throughout the group, the assumptions made and their overall calibration.
(5) The more a firm integrates into its business such economic capital modelling, the more it is likely to focus on managing risks for the benefit of its stakeholders. Consequently, ECMs may produce capital estimates that differ from the amount of capital needed for regulatory purposes. For the FSA to rely on the results of a firm's models, including ECMs, a firm should be able to explain the basis and results of its models and how the amount of capital produced by its models reflects the amount of capital needed for regulatory purposes. It may be that those amounts are not equal. Where they are not equal, the FSA will expect a firm to discuss any differences with the FSA. However, it may prove difficult to reconcile the outcome of a firm's modelling with the FSA's own assessment of the adequacy of that firm's capital. This may be the case when, for instance, matters of judgment are involved in arriving at a firm's capital assessment, or the FSA relies on information which cannot be fully disclosed to the firm (for example comparisons with the firm's peers). Nevertheless, a firm whose ECM produces a different amount of capital to that required for regulatory purposes is still obliged to comply with the overall Pillar 2 rule. A firm should therefore be able to explain to the FSA how the outcome of its ECM is adjusted so that it complies with the overall financial adequacy rule and the overall Pillar 2 rule.
(6) Stress testing should provide senior management with a consolidated view of the amount of risk the firm is or might be exposed to under the chosen stress events. Senior management should therefore be presented with information that considers the possibility of the risks materialising simultaneously in various proportions. For instance, it would be misrepresentative to simulate market risk stressed events without considering that, in those circumstances, market counterparties may be more likely to default. Accordingly, a firm could:

(a) carry out combined stress tests where assets and liabilities are individually subjected to simultaneous changes in two or more risk drivers; for instance, the change in value of each loan made by a firm may be estimated using simultaneous changes to both interest rates and stock market or property values;
(b) integrate the results of market and credit risk models rather than aggregating the results of each model separately; and
(c) consider scenarios which include systemic effects on the firm of wider failures in the firm's market or systems upon which the firm depends and also any possible systemic effects caused by the firm itself suffering losses which affect other market participants which in turn exacerbate the firm's position.

(7) Furthermore, if a complex firm uses an ECM it should validate the assumptions of the model through a comprehensive stress testing programme. In particular this validation should:

(a) test correlation assumptions (where risks are aggregated in this way) using combined stresses and scenario analyses;
(b) use stress tests to identify the extent to which the firm's risk models omit non-linear effects, for instance the behaviour of derivatives in market risk models; and
(c) consider not just the effect of parallel shifts in interest rate curves, but also the effect of curves becoming steeper or flatter.

01/01/2007

Guidance on risks to be covered in an ICAAP

BIPRU 2.2.28

BIPRU 2.2.30 G to BIPRU 2.2.40 G set out guidance on some of the sources of risk identified in the overall Pillar 2 rule. BIPRU 2.2.41 R to BIPRU 2.2.45 G have material relating to a firm with an IRB permission.

01/01/2007

BIPRU 2.2.29

(1) A firm may take into account factors other than those identified in the overall Pillar 2 rule when it assesses the level of capital it wishes to hold. These factors might include external rating goals, market reputation and its strategic goals. However, a firm should be able to distinguish, for the purpose of its dialogue with the FSA, between capital it holds in order to comply with the overall financial adequacy rule, capital that it holds as a capital planning buffer and capital held for other purposes.
(2) The calibration of the CRR assumes that a firm's business is well-diversified, well-managed with assets matching its liabilities and good controls, and stable with no large, unusual or high risk transactions. A firm may find it helpful to assess the extent to which its business in fact differs from these assumptions and therefore what adjustments it might be reasonable for it to make to the CRR to arrive at an adequate level of capital resources.

24/09/2010

Interest rate risk arising from non-trading book activities

BIPRU 2.2.30

A firm should assess its exposure to changes in interest rates, in particular risks arising from the effect of interest rate changes on non-trading book activities that are not captured by the CRR. In doing so, a firm may wish to use stress tests to determine the impact on its balance sheet of a change in market conditions.

01/01/2007

Securitisation risk

BIPRU 2.2.31

A firm should assess its exposure to risks transferred through the securitisation of assets should those transfers fail for whatever reason. A firm should consider the effect on its financial position of a securitisation arrangement failing to operate as anticipated or of the values and risks transferred not emerging as expected.

01/01/2007

Residual risk

BIPRU 2.2.32

A firm should assess its exposure to residual risks that may result from the partial performance or failure of credit risk mitigation techniques for reasons that are unconnected with their intrinsic value. This could result from, for instance, ineffective documentation, a delay in payment or the inability to realise payment from a guarantor in a timely manner. Given that residual risks can always be present, a firm should assess the appropriateness of its CRR against its assumptions which underlie any risk mitigation measures it may have in place.

01/01/2007

Concentration risk

BIPRU 2.2.33

A firm should assess, and monitor, in detail its exposure to sectoral, geographic, liability and asset concentrations. The FSA considers that concentrations in these areas increase a firm's exposure to credit risk. Where a firm identifies such concentrations it should consider the adequacy of its CRR.

01/01/2007

Liquidity risk

BIPRU 2.2.34

In accordance with the overall Pillar 2 rule a firm should consider its exposure to liquidity risk and assess its response should that risk materialise.

01/01/2007

BIPRU 2.2.35

When assessing liquidity risk, a firm should consider the extent to which there is a mismatch between assets and liabilities.

01/01/2007

BIPRU 2.2.36

A firm should also, when assessing liquidity risk, consider the amount of assets it holds in highly liquid, marketable forms that are available should unexpected cash flows lead to a liquidity problem. The price concession of liquidating assets is of prime concern when assessing such liquidity risk and should therefore be built into a firm's ICAAP.

01/01/2007

BIPRU 2.2.37

Some further areas to consider in developing the liquidity risk scenario might include:

(1) any mismatching between expected asset and liability cash flows;
(2) the inability to sell assets quickly;
(3) the extent to which a firm's assets have been pledged; and
(4) the possible need to reduce large asset positions at different levels of market liquidity and the related potential costs and timing constraints.

01/01/2007

Business risk: General

BIPRU 2.2.38

A firm's CRR, being risk-sensitive, may vary as business cycles and economic conditions fluctuate over time. A deterioration in business or economic conditions could require a firm to raise capital or, alternatively, to contract its businesses, at a time when market conditions are most unfavourable to raising capital. Such an effect is known as procyclicality.

01/01/2007

BIPRU 2.2.39

To reduce the impact of cyclical effects, a firm should aim to maintain an adequate capital planning buffer during an upturn in business and economic cycles such that it has sufficient capital available to protect itself in unfavourable market conditions.

24/09/2010

BIPRU 2.2.40

To assess its expected capital requirements over the economic and business cycles, a firm may wish to project forward its financial position taking account of its business strategy and expected growth according to a range of assumptions as to the state of the economic or business environment which it faces. For example, an ICAAP should include an analysis of the impact that the actions of a firm's competitors might have on its performance, in order to see what changes in its environment the firm could sustain. Projections over a three to five year period would be appropriate in most circumstances. A firm may then calculate its projected CRR and assess whether it could be met from expected financial resources. Additional guidance on capital planning over an economic and business cycle can be found in GENPRU 1.2.73A G (Capital planning).

14/12/2009

Business risk: Stress tests for firms using the IRB approach

BIPRU 2.2.41

A firm with an IRB permission must ensure that there is no significant risk that it will not be able to meet its capital resource requirements for credit risk under GENPRU 2.1 (Calculation of capital resources requirements) at all times throughout an economic cycle, including the capital resources requirements for credit risk indicated by any stress test carried out under BIPRU 4.3.39 R to BIPRU 4.3.40 R (Stress tests used in assessment of capital adequacy for a firm with an IRB permission) as being likely to apply in the scenario tested. For the purpose of deciding what capital resources are or will be available to meet those credit risk requirements from time to time a firm must exclude capital resources that are likely to be required to meet its other capital requirements under GENPRU 2.1 at the relevant time. A firm must also be able to demonstrate to the FSA at any time that it is complying with this rule.

01/01/2007

BIPRU 2.2.42

BIPRU 2.2.41 R applies to a firm on a solo basis if BIPRU 4 (IRB approach) applies to it on a solo basis and applies on a consolidated basis if BIPRU 4 does.

01/01/2007

BIPRU 2.2.43

If BIPRU 2.2.41 R applies to a firm on a consolidated basis the following adjustments are made to BIPRU 2.2.41 R in accordance with the general principles of BIPRU 8 (Group risk - consolidation):

(1) references to capital resources are to the consolidated capital resources of the firm's UK consolidation group or, as the case may be, its non-EEA sub-group; and
(2) references to the capital requirements in GENPRU 2.1 (Calculation of capital resources requirements) are to the consolidated capital requirements with respect to the firm's UK consolidation group or, as the case may be, its non-EEA sub-group under BIPRU 8 (Group risk - consolidation).

01/01/2007

BIPRU 2.2.44

If a firm's current available capital resources are less than the capital resources requirement indicated by the stress test that need not be a breach of BIPRU 2.2.41 R. The firm may wish to set out any countervailing effects and off-setting actions that can be demonstrated to the satisfaction of the FSA as being likely to reduce the difference referred to in the first sentence. The FSA is only likely to consider a demonstration of such actions as credible if those actions are set out in a capital management plan based on the procedures in GENPRU 1.2.73A G (Capital planning) and including a plan of the type referred to in GENPRU 1.2.73A G (5) that has been approved by the firm's senior management or governing body.

14/12/2009

BIPRU 2.2.45

The countervailing factors and off-setting actions that a firm may rely on as referred to in BIPRU 2.2.44 G include, but are not limited to, projected balance sheet shrinkage, growth in capital resources resulting from retained profits between the date of the stress test and the projected start of the economic downturn, the possibility of raising new capital in a downturn, the ability to reduce dividend payments or other distributions, and the ability to allocate capital from other risks which can be shown to be negatively correlated with the firm's credit risk profile.

01/01/2007

Systems and controls

BIPRU 2.2.46

A firm may decide to hold additional capital to mitigate any weaknesses in its overall control environment. These weaknesses might be indicated by the following:

(1) a failure by a firm to complete an assessment of its systems and controls to establish whether they comply with SYSC; or
(2) a failure by a firm's senior management to approve its financial results; or
(3) a failure by a firm to consider an analysis of relevant internal and external information on its business and control environment.

01/01/2007

BIPRU 2.2.47

In considering if there are any systems and control weaknesses and their effect on the adequacy of the CRR, a firm should be able to demonstrate to the FSA that all the issues identified in SYSC have been considered and that appropriate plans and procedures exist to deal adequately with adverse scenarios.

01/01/2007

Risks which may be considered according to the nature of the activities of a firm

BIPRU 2.2.48

(1) BIPRU 2.2.49 G to BIPRU 2.2.70 G set out guidance for:

(a) a bank or building society;
(b) an asset management firm; and
(c) a securities firm;

whose activities are either simple or moderately complex.
(2) BIPRU 2.2.49 G to BIPRU 2.2.70 G provide examples of the sorts of risks which such a firm might typically face and of stress tests or scenario analyses which it might carry out as part of its ICAAP.
(3) The material on securities firms is also relevant to a commodities firm.

01/01/2007

Banks and building societies

BIPRU 2.2.49

The FSA considers that the concentration risk resulting from concentrated portfolios is significant for most banks and building societies.

01/01/2007

BIPRU 2.2.50

If a bank or building society chooses to use the CRR as a starting point for its capital assessment, it should remember that, when assessing its exposure to concentration risk, the calculation of the CRR is based on the assumption that a firm is well-diversified.

01/01/2007

BIPRU 2.2.51

In assessing the degree of credit concentration, a bank or building society should consider its degree of credit concentration in a particular economic or geographic area. Where the business of a firm is, by its nature, concentrated (for example, a specialised firm lending to one sector only), a firm should consider the impact of adverse economic factors, such as a rise in unemployment in the area in which it has a concentration of exposures, and its impact on asset quality. A gradual change of cultural environment could also affect a bank or building society and a firm should consider whether this issue should be the subject of scenario analysis.

01/01/2007

BIPRU 2.2.52

Typically, a building society's portfolio is concentrated. The extent to which a building society can diversify its business is limited. A building society should, nevertheless, consider the impact of geographic concentrations on its capital by, for instance, analysing the effect of local economic factors such as unemployment and its impact on arrears, house prices and loan-to-value ratios.

01/01/2007

BIPRU 2.2.53

Similarly, a building society should consider the concentration in its portfolio of certain product types that have, inherently, a more than average risk (for example, lifetime mortgages). It should, through scenario analyses in relation to its portfolio, assess the potential impact on its profitability and capital of those scenarios.

01/01/2007

BIPRU 2.2.54

In relation to BIPRU 10 (Large exposures requirements), a bank or building society should take into account factors such as future business growth and cyclicality when it assesses the amount of capital which it will need to remain in compliance with those rules. A firm may also consider in its assessment whether any large exposures that it has identified are positively correlated.

31/12/2010

BIPRU 2.2.55

Where a bank or building society lends to a counterparty which it assesses as representing a high credit risk, it should assess whether compliance with the rules in BIPRU in relation to credit risk is sufficient for it to manage that risk prudently.

01/01/2007

BIPRU 2.2.56

The performance of specialised portfolios may, in some instances, depend on key individuals. This factor exacerbates concentration risk because the skill of those individuals in part limits the risk arising from a concentrated portfolio. The impact of those individuals is likely to be correspondingly greater in small firms. In developing its stress tests and scenario analyses, a bank or building society should therefore consider the impact of losing key individuals on its ability to operate normally, as well as the direct impact on its revenues.

01/01/2007

BIPRU 2.2.57

A bank or building society should assess the sensitivity of its financial position to adverse movements in interest rates. For instance, a bank or building society should assess its sensitivity to interest rate risk arising from interest rate mismatches between assets and liabilities. A building society is exposed to interest rate risk to the extent that it borrows on a short term basis but lends over a longer period.

01/01/2007

BIPRU 2.2.58

When assessing the adequacy of its capital, a bank or building society should not only consider the vulnerability of its revenue, but also the sensitivity of its funding and, in particular, its ability to raise additional funding in time of economic stress. A bank or building society should therefore consider whether its funding pool is sufficiently diversified. For example, where a bank is reliant solely on its parent to provide funding, its access to funds may be suddenly restricted should the parent's creditworthiness be downgraded. Similarly, a bank or building society may consider the impact of an increase in bond rates or a rating downgrade, if relevant, on its capital cost and its subsequent ability to raise capital.

01/01/2007

BIPRU 2.2.59

A bank or building society should assess the impact of its business plans on its capital over the time horizon which it uses in its business plans. A bank or building society should assess the impact on its capital of diversifying its activities and the risk it runs of failing to manage that new business successfully. For that purpose, it may consider the cost of a price war to enter a new competitive market or the risk of mis-pricing some products as a result of not having sufficient expertise in its new area of business.

01/01/2007

BIPRU 2.2.60

A bank or building society is also exposed to reputational risk, as its ability to underwrite new business is heavily reliant on the standing of the reputation of the firm. A bank or building society may consider the impact on its financial position of legal disputes which damage its reputation.

01/01/2007

An asset management firm

BIPRU 2.2.61

An asset manager is primarily exposed to operational risk and reputational risk.

01/01/2007

BIPRU 2.2.62

When assessing reputational risk an asset manager should consider issues such as:

(1) how poor performance can affect its ability to generate profits;
(2) the effect on its financial position should one or more of its key fund managers leave that firm;
(3) the effect on its financial position should it lose some of its largest customers; and
(4) how poor customer services can affect its financial position; for example, a firm which has outsourced the management of customer accounts may want to consider the impact on its own reputation of the service provider failing to deliver the service.

01/01/2007

BIPRU 2.2.63

As an asset manager's mandates become more complex, the risk of it failing to comply fully with the terms of its contracts increases. In the event of such failure, a firm can be exposed to substantial losses resulting from customers' claims and legal actions. Although the FSA would expect an asset manager to have in place adequate controls to mitigate that risk, it may also like to consider the potential cost to it should customers claim that it has not adhered to mandates. Past claims and compensation may provide a useful benchmark for an asset manager to assess its sensitivity to future legal action. In assessing the adequacy of its capital, an asset manager may therefore consider whether it could absorb the highest operational loss it has suffered over the last 3 to 5 years.

01/01/2007

BIPRU 2.2.64

In relation to the issues identified in BIPRU 2.2.63 G, an asset manager should consider, for example:

(1) the direct cost to it resulting from fraud or theft;
(2) the direct cost arising from customers' claims and legal action in the future; an asset manager could consider the impact on its financial position if a legal precedent were to encourage its customers to take legal action against that firm for failing to advise correctly on a certain type of product; the relevance of such scenarios is likely to depend on whether the asset manager is acting on a discretionary basis or solely as advisor; and
(3) where it has obtained professional indemnity insurance, the deductibles and individual or aggregate limits on the sums insured.

01/01/2007

BIPRU 2.2.65

The FSA expects an asset manager to consider the impact of economic factors on its ability to meet its liabilities as they fall due. An asset manager should therefore develop scenarios which relate to its strategic and business plan. An asset manager might therefore consider:

(1) the effect of a market downturn affecting both transaction volumes and the market values of assets in its funds; in assessing the impact of such a scenario, an asset manager may consider the extent to which it can remain profitable (for example, by rapidly scaling down its activities and reducing its costs);
(2) the impact on current levels of capital if it plans to undertake a significant restructuring; and
(3) the impact on current levels of capital if it plans to enter a new market or launch a new product; it should assess the amount of capital it needs to hold, when operating for the first time in a market in which it lacks expertise.

01/01/2007

A securities firm

BIPRU 2.2.66

(1) A securities firm may consider the impact of the situations listed in (a) to (c) on its capital levels when assessing its exposure to concentration risk:

(a) the potential loss that could arise from large exposures to a single counterparty;
(b) the potential loss that could arise from exposures to large transactions or to a product type; and
(c) the potential loss resulting from a combination of events such as a sudden increase in volatility leaving a hitherto fully-margined client unable to meet the margin calls due to the large size of the underlying position and the subsequent difficulties involved in liquidating its position.

(2) An example of the analysis in (1)(b) relates to a securities firm which relies on the income generated by a large, one-off corporate finance transaction. It may want to consider the possibility of legal action arising from that transaction which prevents the payment of its fees. Additionally, an underwriting firm may, as a matter of routine, commit to place a large amount of securities. It may therefore like to assess the impact of losses arising from a failure to place the securities successfully.

01/01/2007

BIPRU 2.2.67

Where a securities firm deals in illiquid securities (for example, unlisted securities or securities listed on illiquid markets), or holds illiquid assets, potentially large losses can arise from trades that have failed to settle or because of large unrealised market losses. A securities firm may therefore consider the impact of liquidity risk on its exposure to:

(1) credit risk; and
(2) market risk.

01/01/2007

BIPRU 2.2.68

Counterparty risk rules only partially capture the risk of settlement failure as the quantification of risk is only based on mark-to-market values and does not take account of the volatility of the securities over the settlement period. A securities firm's assessment of its exposure to counterparty risk should take into account:

(1) whether it acts as arranger only or whether it also executes trades;
(2) the types of execution venues which it uses; for example, the London Stock Exchange or a retail service provider (RSP) have more depth than multilateral trading facilities; and
(3) whether it offers extended settlements and free delivery compared to delivery versus payment business.

01/11/2007

BIPRU 2.2.69

(1) A securities firm should also consider the impact of external factors on the levels of capital it needs to hold. Scenarios covering such external factors should relate to its strategy and business plan. A securities firm might wish to consider the questions in (2) to (7).
(2) Whether it plans to participate in a one-off transaction that might strain temporarily or permanently its capital.
(3) Whether the unevenness of its revenue suggests that it should hold a capital buffer. Such an assessment could be based, for instance, on an analysis of past revenue and the volatility of its capital.
(4) How its income might alter as interest rates fluctuate where it is obliged to pay interest to its clients in excess of interest it earns on client money deposits.
(5) How its capital would be affected by a market downturn. For instance, how sensitive that firm is to a sharp reduction of trading volumes.
(6) How political and economic factors will affect that firm's business. For instance, a commodity firm may wish to consider the impact of a sharp increase in prices on initial margins and, consequently, on its liquidity.
(7) Whether it anticipates expanding its activities (for example, by offering clearing services), and if so, the impact on its capital.

01/01/2007

BIPRU 2.2.70

A securities firm may also want to assess the impact of its internal credit limits on its levels of capital. For instance, a firm whose internal procedures authorise dealing without cash in the account or without pre-set dealing limits might consider more capital is required than if it operated stricter internal credit limits.

01/01/2007

Capital models

BIPRU 2.2.71

A firm may approach its assessment of adequate capital by developing a model, including an ECM (see BIPRU 2.2.27 G), for some or all of its business risks. The assumptions required to aggregate risks modelled and the confidence levels adopted should be considered by a firm's senior management. A firm should also consider whether any relevant risks, including systems and control risks, are not captured by the model.

01/01/2007

BIPRU 2.2.72

A firm should not expect the FSA to accept as adequate any particular model that it develops or automatically to reflect the results from the model in any individual capital guidance or capital planning buffer. However, the FSA will take into account the results of a sound and prudent model when giving individual capital guidance or when dealing with the firm in relation to its capital planning buffer (see GENPRU 1.2.19 G (Outline of provisions related to GENPRU 2.1 (Adequacy of financial resources))).

24/09/2010

BIPRU 2.2.73

There is no prescribed approach as to how a firm should develop its internal capital model. However, a firm should be able to demonstrate:

(1) the confidence levels set and whether these are linked to its corporate strategy;
(2) the time horizons set for the different types of business that it undertakes;
(3) the extent of historic data used and back-testing carried out;
(4) that it has in place a process to verify the correctness of the model's outputs; and
(5) that it has the skills and resources to operate, maintain and develop the model.

01/01/2007

BIPRU 2.2.74

In relation to the use of an ECM (see BIPRU 2.2.27 G), the FSA is likely to place more reliance on a firm's ICAAP if the firm provides the following information:

(1) a comparison of the amount of capital that the ECM generates in respect of each of the risks captured in the CRR before aggregation with the corresponding components of the CRR calculation; and
(2) evidence that the guidance in BIPRU 2.2.71 G to BIPRU 2.2.78 G has been followed.

01/01/2007

BIPRU 2.2.75

If a firm adopts a top-down approach to developing its internal model, it should be able to allocate the outcome of the internal model to risks it has previously identified in relation to each separate legal entity, business unit or business activity, as appropriate. In relation to a firm which is a member of a group, GENPRU 1.2.53 R (Application of GENPRU 1.2 on a solo and consolidated basis: Processes and tests) sets out how internal capital identified as necessary by that firm's ICAAP should be allocated.

01/01/2007

BIPRU 2.2.76

If a firm's internal model makes explicit or implicit assumptions in relation to correlations within or between risk types, or in relation to diversification benefits between business types, the firm should be able to explain to the FSA, with the support of empirical evidence, the basis of those assumptions.

01/01/2007

BIPRU 2.2.77

A firm's model should also reflect the past experience of both the firm and the sectors in which it operates.

01/01/2007

BIPRU 2.2.78

The values assigned to inputs into a firm's model should be derived either stochastically, by assuming the value of an item can follow an appropriate probability distribution and by selecting appropriate values at the tail of the distribution, or deterministically, using appropriate prudent assumptions. For options or guarantees which change in value significantly in certain economic or demographic circumstances, a stochastic approach would normally be appropriate.

01/01/2007

BIPRU 2.3

Interest rate risk in the non-trading book

01/01/2007

Application

BIPRU 2.3.1

This section of the Handbook applies to a BIPRU firm.

01/01/2007

BIPRU 2.3.2

(1) Interest rate risk in the non-trading book will normally be a major source of risk for:

(a) a bank;
(b) a building society; and
(c) a BIPRU investment firm that deals on own account (including underwriting on a firm commitment basis) and whose non-trading book business equals or exceeds 15% of its total business.

(2) However it will not normally be a significant risk for any other BIPRU investment firm.
(3) The test in (1)(c) should be carried out in the same way as it is for the purpose of the 5% test in BIPRU 1.2.17 R (Definition of the trading book).
(4) Where BIPRU 2.3 is applied on a consolidated basis (see BIPRU 2.3.13 R) the test in (1)(c) should be carried out in the same way as it is under BIPRU 8.7.24 R (Trading book size for the purposes of consolidation).

01/01/2007

BIPRU 2.3.3

Interest rate risk in the non-trading book may arise from a number of sources for example:

(1) risks related to the mismatch of repricing of assets and liabilities and off balance sheet short and long-term positions;
(2) risks arising from hedging exposure to one interest rate with exposure to a rate which reprices under slightly different conditions;
(3) risk related to the uncertainties of occurrence of transactions e.g. when expected future transactions do not equal the actual transactions; and
(4) risks arising from consumers redeeming fixed rate products when market rates change.

01/01/2007

Purpose

BIPRU 2.3.4

BIPRU 2.3 sets out more detail on how the systems and controls requirements in SYSC and GENPRU 1.2.30 R (Processes, strategies and systems for risks) and the requirements about stress and scenario testing in GENPRU 1.2.36 R apply to interest rate risk in the non-trading book.

01/01/2007

BIPRU 2.3.5

BIPRU 2.3 implements Article 124(5) of the Banking Consolidation Directive.

01/01/2007

Proportionality

BIPRU 2.3.6

The guidance on proportionality in BIPRU 2.2 applies to BIPRU 2.3.

01/01/2007

Stress testing for interest rate risk: General requirement

BIPRU 2.3.7

(1) As part of its obligations under GENPRU 1.2.30 R (Processes, strategies and systems for risks) and GENPRU 1.2.36 R (Stress and scenario tests) a firm must carry out an evaluation of its exposure to the interest rate risk arising from its non-trading activities.
(2) The evaluation under (1) must cover the effect of a sudden and unexpected parallel change in interest rates of 200 basis points in both directions.
(3) A firm must immediately notify the FSA if any evaluation under this rule suggests that, as a result of the change in interest rates described in (2), the economic value of the firm would decline by more than 20% of its capital resources.

01/01/2007

BIPRU 2.3.8

A firm should, under BIPRU 2.3.7 R (2), apply a 200 basis point shock to each major currency exposure.

01/01/2007

BIPRU 2.3.9

For a larger and/or more complex firm, appropriate systems to evaluate and manage interest rate risk in the non-trading book should include:

(1) the ability to measure the exposure and sensitivity of the firm's activities, if material, to repricing risk, yield curve risk, basis risk and risks arising from embedded optionality (for example, pipeline risk, prepayment risk) as well as changes in assumptions (for example those about customer behaviour);
(2) consideration as to whether a purely static analysis of the impact on their current portfolio of a given shock or shocks should be supplemented by a more dynamic simulation approach; and
(3) scenarios in which different interest rate paths are computed and in which some of the assumptions (e.g. about behaviour, contribution to risk and balance sheet size and composition) are themselves functions of interest rate level.

14/12/2009

BIPRU 2.3.10

Under GENPRU 1.2.60 R, a firm is required to make a written record of its assessments made under GENPRU 1.2. A firm's record of its approach to evaluating and managing interest rate risk as it affects the firm's non-trading activities should cover the following issues:

(1) the internal definition of and boundary between "banking book" and "trading activities" (see BIPRU 1.2);
(2) the definition of economic value and its consistency with the method used to value assets and liabilities (e.g. discounted cashflows);
(3) the size and the form of the different shocks to be used for internal calculations;
(4) the use of a dynamic and / or static approach in the application of interest rate shocks;
(5) the treatment of commonly called "pipeline transactions" (including any related hedging);
(6) the aggregation of multicurrency interest rate exposures;
(7) the inclusion (or not) of non-interest bearing assets and liabilities (including capital and reserves);
(8) the treatment of current and savings accounts (i.e. the maturity attached to exposures without a contractual maturity);
(9) the treatment of fixed rate assets (liabilities) where customers still have a right to repay (withdraw) early;
(10) the extent to which sensitivities to small shocks can be scaled up on a linear basis without material loss of accuracy (i.e. covering both convexity generally and the non-linearity of pay-off associated with explicit option products);
(11) the degree of granularity employed (for example offsets within a time bucket); and
(12) whether all future cash flows or only principal balances are included.

01/01/2007

BIPRU 2.3.11

The FSA will periodically review whether the level of the shock referred to in BIPRU 2.3.7 R (2) is appropriate in the light of changing circumstances, in particular the general level of interest rates (for instance periods of very low interest rates) and their volatility. A firm's internal systems should therefore be flexible enough to compute its sensitivity to any standardised shock that is prescribed. If a 200 basis point shock would imply negative interest rates or if such a shock would otherwise be considered inappropriate, the FSA will consider adjusting the requirements accordingly.

01/01/2007

Stress testing for interest rate risk: Frequency

BIPRU 2.3.12

(1) A firm must carry out the evaluations required by BIPRU 2.3.7 R as frequently as necessary for it to be reasonably satisfied that it has at all times a sufficient understanding of the degree to which it is exposed to the risks referred to in that rule and the nature of that exposure. In any case it must carry out those evaluations no less frequently than required by (2) or (3).
(2) The minimum frequency of the evaluation in BIPRU 2.3.7 R (1) is once each year.
(3) The minimum frequency of the evaluation in BIPRU 2.3.7 R (2) is once each quarter.

01/01/2007

Consolidation

BIPRU 2.3.13

GENPRU 1.2.45 R to GENPRU 1.2.59 R (Application of GENPRU 1.2 on a solo and consolidated basis) apply to BIPRU 2.3 as they apply to GENPRU 1.2.30 R and GENPRU 1.2.36 R.

01/01/2007