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Creating an Effective ICARA: a practical Guide for Investment Firms

5 and 6 July 2022, Remote

9:30am to 12:45pm each day.

This course has already taken place click here to view our current courses

Outline & Objectives

The ICARA should be the centrepiece of a firm's risk management framework”              FCA

The Investment Firms Prudential Review will replace the ICAAP with the ICARA (Internal Capital and Risk Assessment) under which all investment firms will need to prepare for changes to the way in which they currently calculate their regulatory capital. The ICARA will also apply to firms to whom it has not previously applied.

It is likely the FCA will be using the SREP process actively to monitor the quality of ICARAs as a window into the risk management within firms, through virtual and onsite visits. This reflects the FCA’s post-Covid active interest in firm solvency and wind-down planning.

With the power to make capital guidance legally binding and the impact of the new provisions on group structures affecting where capital is held within a group, the ICARA is an essential document to get right and so demonstrate the quality of your firm’s risk management process and capital allocation decisions.

This practical workshop is designed to equip delegates with an understanding of the relevant rules, practical requirements, and transition considerations.

Making use of case studies throughout, this course will help those attending understand the core requirements and how to pull them together to create an effective ICARA that is more than just a “box-ticking” exercise and which is a useful took for senior management and a defence of the firm’s approach to capital provisioning and risk management.

It will also help delegates understand what to expect from an FCA SREP and how to manage the process effectively.

Attending will help you:

  1. Understand the central role the ICARA is intended to play in the Board’s strategic thinking and risk management activity
  2. Consider the impact of the IFPR and the importance of FG 20/01
  3. Review the regulatory requirements applicable
  4. Examine the practical problems in creating an ICARA and how to overcome them
  5. Develop strategies for risk assessment
  6. Explore firm categorisation and K-Factors
  7. Appreciate the role of stress testing
  8. Construct an appropriate winding-up plan and guidance
  9. Prepare for a SREP

Who will benefit?

This programme is specifically designed for Compliance, Operational Risk and Internal Audit professionals in FCA regulated investment firms subject to the demands of the production, maintenance and review of an ICARA document under the new MiFIDPRU requirements. It will be essential for anyone involved in the transition from the ICAAP to the ICARA

It will also be of value to senior Finance and Chief Operating Officers who are involved in the production of the ICARA and need to understand its place in the control and governance framework.

Training Approach

This course will be delivered via a real time slide sharing and live audio visual platform, accessible by desktop computer, laptop, tablet or smartphone. The same core content will be covered as in the original face to face training course, with the format and style adapted for remote delivery.  

Course Presenter

Gary has over 25 years of compliance experience in the UK and overseas, including spells with the Personal Investment Authority, Henderson Global Investors, Brevan Howard Asset Management, Religare Capital Markets and as a Managing Partner of a boutique financial services firm. He has run his own regulatory and governance consultancy, Tetractys Partners LLP since September 2013. He has extensive asset management, hedge fund and investment banking experience in addition to a broad and deep understanding of corporate governance. Gary is a regular conference speaker and author of technical articles on compliance-related topics. He sits on the regulatory advisory group of the Journal of Securities Operations and Custody. Gary holds Masters degrees from Oxford and London Universities and an MBA from the Open University Business School, is a former director of Cayman and Luxembourg domiciled hedge funds, as well as regulated companies in the UK and South Africa. Gary has been an FSA/FCA registered person in Controlled Functions 10 and/or 11 since 2001. He brings a combination of compliance and commercial experience, in terms of both practical implementation and Board level oversight, to the training he delivers.

Course Programme

Session Aim Content
Central place of the ICAAP/ICARA To consider the role the ICARA plays in linking together multiple aspects of the governance process within firms and how this is intended to be demonstrably at the heart of the senior management decision-making process
  • Appreciating the full scope of the requirements
  • What this means for firms
  • Why firms get it wrong
Regulatory requirements To understand the full extent of the applicable regulatory requirements and how these “plug in” to other key aspects of the Rulebook, including REG DATA reporting
  • Examining the regulatory requirements
  • What firms often miss
  • Where ICARAs are likley to fall short 
Overcoming practical problems To be able to navigate effectively a number of the practical problems that can emerge when constructing an ICARA
  • Real-life examples and how these were overcome
Strategies for risk assessment To understand the various approaches to risk assessment and how these affect the creation of the ICARA
  • The role of Compliance, Operational Risk and Internal Audit
  • Linking risk scoring to fundamental financials
  • Moving from “best guess” to empirical evidence
The role of stress testing To examine the role stress testing plays in the ICARA, strategic decision-making and liquidity management
  • The purpose of stress testing
  • What might constitute meaningful stress tests?
  • The role of mitigation plans
  • The link to the winding-up plan
The winding up plan and guidance
To understand the requirements of the WDP and how this can apply in practice to a firm
  • What is the purpose of the WDPG?
  • Key requirements and applying these in practice
  • Constructing a credible winding-up plan for both normal and stressed conditions
Preparing for the SREP To know what the FCA looks for in the SREP and how firms can be best prepared to manage the process effectively
  • Purpose of the SREP
  • What form does the review take?
  • Timescales and records
  • What is the FCA looking to find?

This course can be delivered in-house at a time and location to suit your business and tailored to suit your people and organisation. We can also create bespoke training when something very specific is needed.Please contact us to discuss your requirements in more detail and at no obligation.

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