Related provisions for BIPRU 2.2.39
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4As 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
4After 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'scapital 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'sSREP) or, in exceptional cases, as a forward looking target that the firm
4Where 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'sICAAP, 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.
4If 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.
4Where 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.
4For 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
Monitoring the use of a firm'scapital 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,
4Consistent 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
4Following 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.
(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
(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.
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 buffer4. 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 buffer4 (see GENPRU 1.2.19 G (Outline of provisions related to GENPRU 2.1 (Adequacy
This section also has rules requiring a firm to carry out appropriate stress tests and scenario analyses for the risks it has previously identified and to establish the amount of financial resources needed in each of the circumstances and events considered in carrying out the stress tests and scenario analyses. In the case of a BIPRU firm, the FSA will consider as part of its SREP whether the BIPRU firm should hold a capital planning buffer and, in such a case, the amount and