WBS ICAAP Submission Portal
1
Overview
Following consultation with credit institutions supervised by Wholesale Banks Supervision
(WBS) the Central Bank of Ireland’s ICAAP Submission Portal for credit institutions (the
Portal) has been updated to ensure that it remains fit for purpose. All credit institutions
supervised by WBS are required to complete this document within timeframes set by their
supervisor.
It is the responsibility of each credit institution to design, implement and maintain the
processes, methodologies and controls that underpin their ICAAPs.
The Central Bank
anticipates that in most organisations, the ‘building’ of the ICAAP will be conducted by
persons with appropriate skills and experience in the organisation. Consistent with the
Central Bank’s Corporate Governance Code and the relevant EBA standards, we expect the
Boards of institutions supervised by WBS to (inter-alia) understand the parameters and key
assumptions underpinning their institution’s ICAAP, to challenge their appropriateness, to
suggest amendments to the framework and to instigate internal and external reviews on their
behalf to ensure that the ICAAP is fit for purpose on an on-going basis. In so doing, the
Board takes ownership and responsibility for the ICAAP. Institutions should note in this
regard that the Portal is a communication tool that describes those processes, methodologies
and controls. A completed Portal therefore does not constitute a functioning ICAAP.
The ICAAP Submission Portal will form an integral part of all stages of the supervisory
dialogue between your institution and the Central Bank of Ireland. Following its initial
review your Examination Team will request further supporting documentation and data.
Our interaction with you will assess the following in particular:

The extent to which each institution’s Board and senior management have taken
responsibility for the ICAAP.

The extent to which the design of the ICAAP has been fully specified and
documented.

The extent to which the ICAAP is used to inform decision-making.
2

The extent to which the ICAAP is risk-based.

The extent to which the ICAAP is reviewed.

The comprehensiveness of the coverage of the ICAAP.

The adequacy of measurement and assessment processes.

The adequacy of your institution’s capital.
3
Contents
Page
1.
General and Miscellaneous
5
2.
Business Profile
6
3.
Governance and Integration
7
4.
Risk Materiality and Appetite
11
5.
Individual Risks
15
6.
Stress Testing
32
7.
Capital Strategy
35
8.
Capital
37
9.
Review Process
39
10.
Future Plans
41
11.
Sign-Off
42
4
1.
General and Miscellaneous
1.1
Please name the licensed entity or entities to which this submission refers.
1.2
Please provide the date of the institution’s Board meeting during which this ICAAP
submission was reviewed. Please enclose a copy of the relevant minute of the Board
meeting.
1.3
Please provide the following details for the key contact in your institution on
ICAAP related issues:
Name
Job Title
Department
Postal Address
Phone Number
Fax Number
E-Mail
1.4
Please provide the following details for the key contacts in the regulatory authority
of your parent institution (if applicable) and your subsidiaries (if applicable):
Name
Job Title
Department
Postal Address
Phone Number
Fax Number
E-Mail
5
2.
Business Profile
2.1
Please enclose a copy of your institution’s business strategy and business plan. Please
state the date of the Board meeting during which it was approved and provide a
copy of the minutes of the meeting.
2.2
Please provide data in the following table on all business lines of the entity:
Business Line
% of Overall Revenue %
of
in the Last Financial Revenue
Overall
in
Year
Year to Date
100%
100%
the
Please provide also the definition of revenue you have used to complete this question.
2.3
Please provide an assessment of your institution’s performance by business line in the
last financial year and the year to date.
2.4
Please provide an assessment of your institution’s profitability in the last financial
year and the year to date.
2.5
Please provide a breakdown of your institution’s funding at the most recent available
date.
6
3.
Governance and Integration
3.1
Board & Committees
3.1.1 Please enclose a copy of your institution’s organisation charts identifying the
interface between the Board, Board sub-committees and all management
committees. These charts should also provide the reporting lines of the Chief Risk
Officer, the Compliance Officer, the Head of Internal Audit and key business
unit/overseas branch heads.
3.1.2 Please provide the names and roles/job titles of all current members of the Board, the
Board sub-committees and management committees.
3.1.3 Please provide the following information about the charters/terms of reference of your
institution’s Board, Board sub-committees and management committees:
Document
Reference
Title
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
7
3.1.4 Please identify any changes which have been made to the composition and structure
of the Board, Board sub-committees and management committees since the last
submission of your institution’s ICAAP Portal.
3.1.5 Please outline how the effectiveness of the Board and its sub-committees is
monitored.
3.1.6 If your institution is a subsidiary, please identify the reporting lines (if any) into the
Group of (i) the Board and management sub-committees (ii) the individuals you
have identified in question 3.1.2 and (iii) the Chief Risk Officer, the Compliance
Officer and the Head of Internal Audit.
3.2
Design & Approval of the ICAAP
3.2.1 Please identify all functions that had a role in the design of the current ICAAP and
include narrative that provides a comprehensive overview of that role.
3.2.2 Please describe how your institution’s Board satisfies itself that the scope,
methodology and objectives of the current ICAAP are appropriate. In your answer,
please provide evidence of the discussion and challenge of the ICAAP that took
place at the relevant Board meetings.
3.2.3 Please describe the role of senior management in the design of the current
ICAAP.
Reference should be made in your response to (inter-alia), any training and
familiarisation programmes provided to senior management.
8
3.3
Utilisation of ICAAP Results
3.3.1 Please describe how the Board and its sub-committees utilise the ICAAP results in
decision making about risk. Please provide relevant examples.
3.4
Documentation
3.4.1 Please provide the following information about the document(s) approved by the
Board specifying the scope, methodology and objectives of the current ICAAP:
Document
Reference
Title
Board
Date of Last
Date of Next
Distribution
Approval
Review
Review
List
Date
3.4.2 Please provide the following information about all other documentation that specifies
the scope methodology and objectives of the current ICAAP:
Document
Reference
Title
Date of
Date of Next
Last
Review
Distribution List
Review
9
3.4.3 Please provide the following information with respect to all reports generated by the
ICAAP that are sighted by the Board. Under report description, describe the role of
each report from the perspective of the Board:
Report
Report
Produced
Reference
Description
By
Sighted By
Frequency of
Distribution
Distribution
List
10
4.
Risk Materiality and Appetite
4.1
Risk Materiality
4.1.1 In the table below, please list all material risk types to which your institution is
currently exposed in order of their priority with the most material being listed first:
Risk
1
2
3
4
5
6
7
4.1.2 Please outline your institution’s definition of risk materiality from both a qualitative
and a quantitative perspective.
4.1.3 Please describe how materiality was determined referencing key discussions and
challenge at Board/Board sub-committee level since the date of the last submission of
your institution’s ICAAP Portal. The role of senior management should be given
particular attention in your response.
4.1.4 Please identify any changes to your definition of risk materiality since the last
submission of your institution’s ICAAP Portal.
11
4.1.5 Please provide, in the table below, the following information pertaining to your
institution’s documents that define risk materiality:
Document
Title
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
Reference
(Board,
Risk
Committee
etc.)
4.1.6 For each of your institution’s material risks, please provide the following information:
Risk
Type
Definition
Documented
Time
Policy/
Approved
Date of
Date of
Distribu
Policy/
Horizon
Strategy
By and
Last
Next
tion List
Strategy
of
Reference
Date
Review
Review
(Y/N)
Strategy
4.1.7 For those risks which were deemed immaterial, please provide a reasoned analysis of
how a determination of immateriality was reached.
12
4.2
Risk Appetite
4.2.1 Please provide your institution’s quantitative and qualitative definition of risk
appetite.
4.2.2 Please detail your institution’s risk appetite for each of its material risks.
4.2.3 On a per risk basis, please describe how the risk appetite has changed since the last
submission of your institution’s ICAAP Portal.
4.2.4 Please provide the following information about documents detailing your institution’s
risk appetite:
Document
Reference
Title
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
4.2.5 Please describe how your institution’s Board satisfies itself that the business strategy
is appropriate for the risk appetite. In your answer, please provide detail of the
discussion and challenge of the matter at Board meetings that have taken place since
the last submission of your institution’s ICAAP Portal.
13
4.3
Other
4.3.1 Please identify those Board members who possess specific risk management skills
and experience and outline the skills and experience possessed.
4.3.2 Please provide an overview of risk/ICAAP training provided to Board members since
the last submission of your institution’s ICAAP Portal. In addition please provide an
overview of other supports available to independent non executive directors on risk
matters.
14
5.
Individual Risks
5.1
Credit Risk
5.1.1 Please identify the sources of your institution’s credit risk referring to (inter alia)
portfolio risk and product type.
Risk Measurement
5.1.2 Please set out clearly the processes and the methodologies currently employed to
measure credit risk and the level at which it is measured (transaction, portfolio etc).
5.1.3 If processes and methodologies (ECAP models etc.) used in your institution for the
measurement of credit risk are dependent upon or driven by parent/group processes
and methodologies, please describe how these processes and methodologies
were determined to be appropriate for your institution.
5.1.4 Please describe any substantive changes to the processes and methodologies used to
measure credit risk since the last submission of your institution’s ICAAP Portal.
5.1.5 Please outline the major differences between the Pillar 1 and Pillar 2 processes and
methodologies used to measure credit risk.
Risk Monitoring
5.1.6 Please describe how credit risk is monitored at transaction and portfolio level
referencing in particular:

the key departments/units/sections involved

reporting lines
15

the key reports generated including but not limited to watch lists, non
performing loans, restructuring and provisioning levels

all controls surrounding the monitoring process

any other information you deem relevant
5.1.7 For each of the key reports identified in Question 5.1.6, please provide the following
information:
Report Title
Circulation List
Frequency of
Circulation
5.1.8 Please identify the committee responsible for monitoring credit risk and enclose a
copy of the terms of reference for this committee highlighting therein all references
to the committee’s risk monitoring function.
5.1.9 Please describe any substantive changes to the process for monitoring credit risk
since the last submission of your institution’s ICAAP Portal.
Risk Management/Mitigation
5.1.10 Please describe how credit risk is managed/mitigated at transaction and portfolio
level referencing in particular:

The role of the Board and Board sub-committees in managing/mitigating
credit risk

The role of key individuals and departments in managing/mitigating credit risk
16

All relevant reports circulated to the Board, Board sub-committees and
management committees

Key limits (including concentration limits)

The process for the reporting and resolution of limit breaches

Staff training
5.1.11 For each of the key reports identified in Question 5.1.10, please provide the
following:
Title
Circulation List
Frequency of
Circulation
5.1.12 Please identify the mitigants used by your institution in the management of credit risk
(e.g. hedging products, securitisation, business insurance and other methods that
reduce risk) and the extent and purpose of their use.
5.1.13 In those areas where risk mitigation is not determined to be necessary for this risk,
please provide the rationale for this determination.
5.1.14 Please describe any substantive changes to credit risk management since the last
submission of your institution’s ICAAP Portal, including but not limited to
credit risk appetite and limits.
17
Procedures
5.1.15 Please provide the following data on all procedures documents underpinning the
measurement, monitoring and management of credit risk:
Document
Title
Reference
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
Board Oversight
5.1.16 Please outline how the Board satisfies itself that it has received the requisite data to
carry out its oversight function in relation to credit risk.
Capital
5.1.17 With reference to your response to Question 5.1.2, please provide a description of
how the capital for credit risk was determined to be adequate (to include an analysis
of correlation and diversification benefits and other determinants if applicable).
18
5.2
Market Risk
5.2.1 Please identify the sources of your institution’s market risk referring to (inter alia)
proprietary trading, product type and customer driven exposure.
Risk Measurement
5.2.2 Please set out clearly the processes and the methodologies currently employed to
measure market risk and the level at which it is measured (transaction, portfolio etc).
5.2.3 If processes and methodologies (VaR models, pricing models etc.) used in your
institution for the measurement of market risk are dependent upon or driven by
parent/group processes and methodologies, please describe how these processes and
methodologies were determined to be appropriate for your institution.
5.2.4 Please describe any substantive changes to the processes and methodologies used to
measure market risk since the last submission of your institution’s ICAAP Portal.
5.2.5 Please outline the major differences between the Pillar 1 and Pillar 2 processes and
methodologies used to measure market risk.
Risk Monitoring
5.2.6 Please describe how market risk is monitored at transaction and portfolio level
referencing in particular:

the key departments/units/sections involved

reporting lines

the key reports generated including but not limited to independent price
verification/pricing sources, mark-to-model valuation, real time pricing, real
time limit utilisation, exception reports and limit breaches
19

the use of straight-through processing

the accountancy treatment used in relation to instruments in the trading book

the process for the reporting and resolution of limit breaches

all controls surrounding the monitoring process

any other information you deem relevant
5.2.7 For each of the key reports identified in Question 5.2.6, please provide the following
information:
Report Title
Circulation List
Frequency of
Circulation
5.2.8 Please identify the committee responsible for monitoring market risk and enclose a
copy of the terms of reference for this committee highlighting therein all references
to the committee’s risk monitoring function.
5.2.9 Please describe any substantive changes to the process for monitoring market risk
since the last submission of your institution’s ICAAP Portal.
Risk Management/Mitigation
5.2.10 Please describe how market risk is managed/mitigated at transaction and portfolio
level referencing in particular:

The role of the Board and Board sub-committees in managing/mitigating
market risk

The role of key individuals/units in managing/mitigating market risk

Structure and reporting lines of front, middle and back office functions
20

All relevant reports circulated to the Board, Board sub-committees and
management committees

Key limits

Staff training
5.2.11 For each of the key reports identified in Question 5.2.10, please provide the
following:
Title
Circulation List
Frequency of
Circulation
5.2.12 Please identify the mitigants used by your institution in the management of market
risk (e.g. hedging activity and type of hedges employed, control and limit structure
and other methods that reduce risk) and the extent and purpose of their use.
5.2.13 In those areas where risk mitigation is not determined to be necessary for this risk,
please provide the rationale for this determination.
5.2.14 Please describe any substantive changes to market risk management since the last
submission of your institution’s ICAAP Portal including but not limited to
market risk
appetite and limits.
21
Procedures
5.2.15 Please provide the following data on all procedures documents underpinning the
measurement, monitoring and management of market risk:
Document
Title
Reference
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
Board Oversight
5.2.16 Please demonstrate how the Board satisfies itself that it has received the requisite data
to carry out its oversight function in relation to market risk.
Capital
5.2.17 With reference to your response to Question 5.2.2, please provide a description of
how the capital for market risk was determined to be adequate (to include an analysis
of correlation and diversification benefits and other determinants if applicable).
22
5.3
Operational Risk
5.3.1 Please identify your institution’s sources and types (e.g. fraud risk) of operational
risk.
Risk Measurement
5.3.2 Please set out clearly the processes and the methodologies currently employed to
measure operational risk and the level at which it is measured (transaction, portfolio
etc).
5.3.3 If processes and methodologies (ECAP models etc.) used in your institution for the
measurement of operational risk are dependent upon or driven by parent/group
processes and methodologies, please describe how these processes and methodologies
were determined to be appropriate for your institution.
5.3.4 Please describe any substantive changes to the processes and methodologies used to
measure operational risk since the last submission of your institution’s ICAAP Portal.
5.3.5 Please outline the major differences between the Pillar 1 and Pillar 2 processes and
methodologies used to measure operational risk.
Risk Monitoring
5.3.6 Please describe how operational risk is monitored referencing in particular:

the key departments/units/sections involved

reporting lines

the key reports generated including reports on operational risk incidents and
the associated financial consequences including but not limited to impact on
provisioning

the role of the event loss database
23

all controls surrounding the monitoring process

any other information you deem relevant
5.3.7 For each of the key reports identified in Question 5.3.6, please provide the following
information:
Report Title
Circulation List
Frequency of
Circulation
5.3.8 Please identify the committee responsible for monitoring operational risk and enclose
a copy of the terms of reference for this committee highlighting therein all references
to the committee’s risk monitoring function.
5.3.9 Please describe any substantive changes to the process for monitoring operational risk
since the last submission of your institution’s ICAAP Portal.
Risk Management/Mitigation
5.3.10 Please describe how operational risk is managed/mitigated referencing in particular:

The role of the Board and Board sub-committees in managing/mitigating
operational risk

The role of key individuals and departments in managing/mitigating
operational risk

All relevant reports circulated to the Board, Board sub-committees and
management committees

The parameters of the operational risk database

Key limits around loss events and reporting thereof

The process for the reporting and resolution of limit breaches
24

Staff training
5.3.11 For each of the key reports identified in Question 5.3.10, please provide the
following:
Title
Circulation List
Frequency of
Circulation
5.3.12 Please identify the mitigants used by your institution in the management of
operational risk (e.g. business insurance, disaster recovery site, BCP etc.) and the
extent and purpose of their use.
5.3.13 In those areas where risk mitigation is not determined to be necessary for this risk,
please provide the rationale for this determination.
5.3.14 Please describe any substantive changes to operational risk management since the
most recent submission of your institution’s ICAAP Portal including but not limited
to operational risk appetite and limits.
25
Procedures
5.3.15 Please provide the following data on all procedures documents underpinning the
measurement, monitoring and management of operational risk:
Document
Title
Reference
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
Board Oversight
5.3.16 Please demonstrate how the Board satisfies itself that it has received the requisite data
to carry out its oversight function in relation to operational risk.
Capital
5.3.17 With reference to your response to Question 5.3.2, please provide a description of
how the capital for operational risk was determined to be adequate (to include an
analysis of correlation and diversification benefits and other determinants if
applicable).
26
Outsourcing
5.3.18 Please complete the following table with regard to your institution’s key risk, business
and control activities that are outsourced to a third party or intra-group:
Outsourced Provider
Governed by
Date of Last
Date of Next
Activity
Service Level
Review of SLA
Review of
Agreement (Y/N)
SLA
27
5.4
Other Material Risks
The following questions should be answered on an individual risk basis for all material
risks to which your institution is exposed excluding credit, market and operational risk.
This Section should also be completed for concentration risk to the extent that this risk
has not been covered in other parts of Section 5. Please copy and complete this section
for each of those risks.
5.4.1 Please identify the sources of your institution’s _______ risk.
Risk Measurement
5.4.2 Please set out clearly the processes and the methodologies currently employed to
measure _____ risk and the level at which it is measured (transaction, portfolio etc).
5.4.3 If processes and methodologies (ECAP models etc.) used in your institution for the
measurement of ______ risk are dependent upon or driven by parent/group processes
and methodologies, please describe how these processes and methodologies
were determined to be appropriate for your institution.
5.4.4 Please describe any substantive changes to the processes and methodologies used to
measure _____ risk since the last submission of your institution’s ICAAP Portal.
Risk Monitoring
5.4.5 Please describe how _____ risk is monitored at transaction and portfolio level
referencing in particular:

the key departments/units/sections involved

reporting lines

the key reports generated
28

all controls surrounding the monitoring process

any other information you deem relevant
5.4.6 For each of the key reports identified in Question 5.4.5, please provide the following
information:
Report Title
Circulation List
Frequency of
Circulation
5.4.7 Please identify the committee responsible for monitoring _____ risk and enclose a
copy of the terms of reference for this committee highlighting therein all references
to the committee’s risk monitoring function.
5.4.8 Please describe any substantive changes to the process for monitoring _____ risk
since the last submission of your institution’s ICAAP Portal.
Risk Management/Mitigation
5.4.9 Please describe how _____ risk is managed/mitigated at transaction and portfolio
level referencing in particular:

The role of the Board and Board sub-committees in managing/mitigating ______ risk

The role of key individuals/units in managing/mitigating ______ risk

All relevant reports circulated to the Board, Board sub-committees and management
committees

Key limits

The process for the reporting and resolution of limit breaches
29

Staff training
5.4.10 For each of the key reports identified in Question 5.4.9, please provide the following
information:
Title
Circulation List
Frequency of
Circulation
5.4.11 Please identify the mitigants used by your institution in the management of _____
risk (e.g. hedging products, securitisation, business insurance and other methods that
reduce risk) and the extent and purpose of their use.
5.4.12 In those areas where risk mitigation is not determined to be necessary for this risk,
please provide the rationale for this determination.
5.4.13 Please describe any substantive changes to the process for managing/mitigating
_____ risk since the most recent submission of your institution’s ICAAP Portal.
30
Procedures
5.4.14 Please provide the following data on all procedures documents underpinning the
measurement, monitoring and management of _____ risk:
Document
Title
Reference
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
Board Oversight
5.4.15 Please demonstrate how the Board satisfies itself that it has received the requisite data
to carry out its oversight function in relation to _______ risk.
Capital
5.4.16 With reference to your response to Question 5.4.2, please provide a description of
how the capital for _____ risk was determined to be adequate (to include an analysis
of correlation and diversification benefits and other determinants if applicable).
31
6.
Stress Testing
6.1
Design & Approval of the Stress Testing Framework
6.1.1 Please identify all functions that had a role in the design of the current stress scenarios
and include narrative that provides a comprehensive overview of that role.
6.1.2 Please describe how your institution’s Board and/or its sub-committees satisfies itself
that the stress testing scenarios and methodologies used are appropriate. In your
answer, please provide detail of the discussion and challenge of the scenarios and
methodologies that took place at the relevant Board and/or Board sub-committee
meetings since the last submission of your institution’s ICAAP Portal.
6.1.3 Please provide the following information about the document(s) approved by the
Board specifying the scope, methodology and objectives of the stress testing
framework:
Document
Reference
Title
Board
Date of Last
Date of Next
Distribution
Approval
Review
Review
List
Date
32
6.2
Scenarios
6.2.1 Please provide the following information about all stress tests your institution
conducts on a scheduled basis:
Stress Risk(s)
Test
Portfolio(s) Frequency Reference
Stressed Stressed
of Testing
Frequency Parties
Date
Date of
for
with
to the
of Last
Next
Document
Which
Review Review Review
Containing Scenario
Scenario
is
Reviewed
6.2.2 Please describe how the stress testing framework assesses the impact of stress testing
upon the following:

Regulatory capital

Balance sheet

P&L

Liquidity
33
6.3
Decision Making
6.3.1 Please provide the following information about the documents containing the results
of the stress tests that are sighted by the Board and/or its sub-committees:
Document
Title
Circulated to:
Reference
Frequency of
Circulation
6.3.2 Please describe how the results of the stress tests are used in decision making about
capital. Please provide examples.
6.3.3 Please describe how the results of the stress tests are used in other forms of decision
making. Please provide examples.
6.3.4 Does your institution conduct reverse stress testing? If yes, please provide details. If
no, please provide an overview of your institution’s future plans to conduct reverse
stress testing.
34
7.
Capital Strategy
7.1
Please provide your capital forecasts for the next three years and the detailed
assumptions underlying these forecasts including but not limited to risks identified
and potential new risks.
7.2
Please provide detail about the documents outlining the capital forecasts below:
Document
Reference
Title
Approval
Approval
Date of
Date of
Distribution
Level
Date
Last
Next
List
Review
Review
(Board,
Risk
Committee
etc.)
7.3
Please set out any capital actions (i.e. increases/decreases in capital required) over
the time horizon of the forecasts you have detailed in Question 7.1.
7.4
Please outline the significant changes to the capital strategy/capital plan since the last
submission of your institution’s ICAAP Portal.
7.5
Please describe the role of all local and group functions and committees responsible
for developing the capital/capital maintenance plan.
35
7.6
Please provide the minutes of all Board/Board sub-committee meetings at which the
capital plan was discussed and/or approved since the date of the last submission of
your institution’s ICAAP Portal.
7.7
Please describe the role of your parent/group in the approval process referencing in
particular your parent’s/group’s support of the capital strategy.
36
8.
Capital
8.1
Please state the date at which the information in this section is provided.
8.2
Please state your institution’s total own funds as at the date above.
8.3
Please provide a detailed breakdown of the constituents of your institution’s capital,
including reference to all tiers and the constituents within these tiers.
8.4
Please complete the following table as per the date stated in Question 8.1 above
above for all material risks to which your institution is currently exposed:1
Risk Type
8.5
Regulatory Capital
Internal Capital
Please complete the following table for all material risks to which your institution was
exposed as at the date of the last submission of your institution’s ICAAP Portal:
Risk Type
1
Regulatory Capital
Internal Capital
In the Regulatory Capital column, institutions should stipulate the regulatory capital for each risk as determined by regulatory capital
methodologies (IRB etc.). In the Internal Capital column, institutions should stipulate the capital for each risk determined by internal
methodologies (e.g. ECAP models). For some institutions, the regulatory and internal methodologies may be one and the same.
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8.6
Does your institution hold capital that may need to be grandfathered under CRD II or
CRD IV/Basel 3? If yes, please provide details.
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9.
Review Process
9.1
Since the last submission of your institution’s ICAAP Portal, please describe any and
all internal and external reviews of the ICAAP that your institution has undertaken
with reference in particular to their scope, objectives, methodologies and the role of
all parties to the review. In preparing your response, please give due consideration in
particular to ICAAP Principle 5 in the European Banking Authority’s paper entitled
‘Guidelines on the Application of the Supervisory Review Process Under Pillar 2’ (25
January 2006).
9.2
Please describe how your institution determines and maintains the independence of
the reviewers.
9.3
Please complete the following table with respect to the documents presented to the
Board and Board sub-committees detailing the findings of all reviews since the last
submission of your institution’s ICAAP Portal:
Document Ref
Title
Prepared By
Completion
Distribution List
Date
9.4
Please describe the actions (if any) taken to follow up on the findings of the reviews
identified in Question 9.1. Please report on the state of any outstanding items.
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9.5
Please provide information in the table below pertaining to reviews of your
institution’s operations against all the standards and guidelines of the CEBS/European
Banking Authority that were conducted in the previous three years:
CEBS/EBA Date of
Conducted
Report
Sighted
Circulated
Guideline
By
Reference
By
To
Review
Please identify the Guidelines your institution determined were not relevant to its
operations and provide the rationale for this determination
9.6
Please provide the following data on all internal audit reports pertaining to ICAAP
produced since the last submission of your institution’s ICAAP Portal. In addition,
please enclose an explanation of your audit ratings:
Report
Reference
Title
Date of
Audit
Number of Open
Audit
Rating
Audit Items
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10. Future Plans
10.1
Please describe any enhancements your institution plans to make to its ICAAP
policies, processes and procedures over the next two years and the timelines for
achieving the stated changes.
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11.
Sign Off
I have reviewed this document in detail and I can confirm that to the best of my knowledge
and belief, the data provided in it is complete and accurate.
____________________
Chief Executive Officer
I have reviewed this document in detail and I can confirm that to the best of my knowledge
and belief, the data describing the role of the Board and its sub-committees in the
development, oversight and approval of the ICAAP is complete and accurate.
___________________
Chairman on behalf of the Board
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