Case of NBR

III. Legal basis for ICAAP, ILAAP and SREP (9)
‣ The banking law requires that NBR uses the SREP approach, which includes
provisions on corporate governance.
‣ At the institution level, SREP guidelines require that the following aspects be
reviewed:
overall internal governance framework;
corporate and risk culture;
organization and functioning of the management body;
remuneration policies and practices;
risk management framework, including ICAAP and ILAAP;
internal control framework, including internal audit function;
information systems and business continuity; and
recovery planning arrangements.
‣ The SREP establishes the expectations for banks to fully consider all risks to
capital within its ICAAP and to liquidity in the ILAAP
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