Introduction
As the financial landscape continues to evolve, investment firms operating under the Investment Firm Prudential Regime (IFPR) face ongoing regulatory challenges. A year on from the IFPR implementation, MIFIDPRU investment firms are now gearing up for their Internal Capital Adequacy and Risk Assessments (ICARAs) in preparation for the upcoming MIF007 return deadline. In this blog, we will explore the significance of the ICARA submission and the heightened expectations set by the Financial Conduct Authority (FCA) in light of recent guidance.
ICARA: An Integral Component of Regulatory Compliance
The ICARA submission, a critical component of the regulatory framework, provides a comprehensive assessment of investment firms' internal capital and risk management framework. Its primary purpose is to ensure that firms maintain sufficient capital buffers to withstand potential losses arising from operational and market risks.
Post-IFPR Implementation Expectations
The FCA's expectations for the ICARA process have evolved since its initial introduction. MIFIDPRU investment firms are now expected to incorporate the findings from the recent "IFPR implementation observations" guidance into their assessments. This indicates a greater focus on ensuring firms adapt to the changing regulatory landscape and implement the necessary adjustments to their risk management practices.
Incorporating Material Changes
Furthermore, firms are required to incorporate any material changes to their business models, size, scale, and complexity in the updated ICARA documents. The FCA expects firms to go beyond the minimum requirements and take proactive steps to set their overall own funds and liquidity requirements. This involves quantifying residual risks of harm through stress testing and wind-down planning.
Ongoing Review and Integration
The ICARA process should not be treated as a one-time task. Rather, it is an ongoing process that requires continual review and integration into a firm's risk management practices throughout the year. The document should comprehensively outline the firm's approach to managing risk, capital, and liquidity, as well as its strategy for mitigating potential harms.
Moving Beyond Minimum Requirements
To ensure compliance and demonstrate a commitment to robust risk management, investment firms should strive to exceed the minimum requirements set by the FCA. Proactively identifying and addressing potential risks and vulnerabilities will strengthen the firm's overall resilience and compliance posture.
Conclusion
As investment firms prepare for their ICARA submission MIF007 post-IFPR implementation, adherence to regulatory guidelines and expectations is paramount. The ICARA process serves as a crucial tool for firms to assess their risk profiles, capital adequacy, and liquidity requirements. By incorporating material changes, going beyond minimum requirements, and ensuring ongoing review and integration, firms can effectively meet regulatory expectations and safeguard their stability.
As the financial landscape continues to evolve, investment firms must remain proactive in their approach to risk management and compliance. By embracing the ICARA submission process and leveraging it as an opportunity for continual improvement, firms can strengthen their resilience and uphold their commitment to customer protection and regulatory compliance.
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