The FSA has issued a paper setting out its observations on ICAAP submissions that have been submitted by Limited Licence firms.
Areas commented on include:
- Lack of clarity in terms of presentation of key information
- Insufficient analysis of wind-down costs
- Firms need to demonstrate that the ICAAP is integrated into the management decision-making process
- Some ICAAP submissions not formally signed off by board etc.
The paper also includes some brief case studies for the benefit of firms.
The last page contains comments on Pillar 3 disclosure; the FSA suggest that making a P3 ‘on request’ does not meet with their approval.
The links below will take you to the paper as well as to the last published ICAAP observations that were published in 2007.