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CP13/6 - CRD IV for Investment Firms - Financial Conduct Authority

CP13/6 - CRD IV for Investment Firms - Financial Conduct Authority

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FCA 2013/xx<br />

(4) that it has in place a process to verify the correctness of the model's<br />

outputs; and<br />

(5) that it has the skills and resources to operate, maintain and develop the<br />

model.<br />

2.3.71 G In relation to the use of an ECM (see IFPRU 2.3.36G), the FCA is likely to<br />

place more reliance on a firm's ICAAP if the firm provides the following<br />

in<strong>for</strong>mation:<br />

(1) a comparison of the amount of capital that the ECM generates in<br />

respect of each of the risks captured in the own funds requirements<br />

be<strong>for</strong>e aggregation with the corresponding components of the own<br />

funds requirements calculation; and<br />

(2) evidence that the guidance in IFPRU 2.3.66G to IFPRU 2.3.73G has<br />

been followed.<br />

2.3.72 G If a firm adopts a top-down approach to developing its internal model, it<br />

should be able to allocate the outcome of the internal model to risks it has<br />

previously identified in relation to each separate legal entity, business unit or<br />

business activity, as appropriate. For a firm which is a member of a group,<br />

IFPRU 2.2.54R (Application of IFPRU 2.2 on an individual basis and<br />

consolidated basis) sets out how internal capital identified as necessary by that<br />

firm's ICAAP should be allocated.<br />

2.3.73 G If a firm's internal model makes explicit or implicit assumptions in relation to<br />

correlations within or between risk types, or in relation to diversification<br />

benefits between business types, the firm should be able to explain to the FCA,<br />

with the support of empirical evidence, the basis of those assumptions.<br />

2.3.74 G A firm's model should also reflect the past experience of both the firm and the<br />

sectors in which it operates.<br />

2.3.75 G The values assigned to inputs into a firm's model should be derived either<br />

stochastically, by assuming the value of an item can follow an appropriate<br />

probability distribution and by selecting appropriate values at the tail of the<br />

distribution, or deterministically, using appropriate prudent assumptions. For<br />

options or guarantees which change in value significantly in certain economic<br />

or demographic circumstances, a stochastic approach would normally be<br />

appropriate.<br />

[2.4 Reporting of breaches<br />

2.4.1 R (1) A firm must have in place appropriate procedures <strong>for</strong> its employees to<br />

report breaches internally through a specific, independent and<br />

autonomous channel.<br />

(2) The channel in (1) may be provided through arrangements provided <strong>for</strong><br />

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