Firm type:
1. Firm
2. Activities
3. Scenarios
4. Market VaR
5. Counterparty
6. OFTR
7. Adequacy
8. Liquidity
9. Stress
10. Wind-down
11. Generate
1
Firm Profile SNI & Non-SNI
Legal identity, entities, accounting reference date and board sign-off
Firm details
Regulated entities
Senior management responsibility
2
Business Model & Activities SNI & Non-SNI
MiFID activities, client types, AUM, K-factor mapping
Regulated activities (select all that apply)
Client types
Retail clients
Professional clients
Eligible counterparties
K-Factor inputs (Pillar 1 — from finance)
£
£
Pillar 1 base = max(PMR, KFR, FOR)
3
Risk Scenarios & Correlation SNI & Non-SNI
Severe but plausible scenarios, K-factor assignment, capital estimates and aggregation
Assign each scenario to a K-factor column. The correlation aggregation (driver overlap model) will compute diversified capital per K-factor — producing Tables 1 and 2 of the ICARA.
Scenario aggregation method
Method:
Table 1 — Standalone own funds requirement by K-factor (£)
Driver weights — common root causes
Table 2 — Aggregated requirement after correlation diversification (£)
Appendix — Correlation methodology: how the diversification benefit is calculated
Step 1 — Driver exposure matrix

Each scenario is characterised by its exposure to ${() => S.drivers.length}() common risk drivers (e.g. People/Process, Technology, Control Environment). Exposures are scored on a four-point ordinal scale — None (0), Low (1), Medium (2), High (3) — and mapped to continuous values via the vector L = [0, 0.3, 0.6, 1.0]. This produces a scenario-driver matrix B of dimension (N scenarios × K drivers), where Bik ∈ {0, 0.3, 0.6, 1.0}.

Step 2 — Pairwise correlation via weighted Jaccard similarity

The pairwise correlation between scenarios i and j is computed as a weighted Jaccard overlap of their driver exposure profiles:

ρij = Σk wk · min(Bik, Bjk) / Σk wk · max(Bik, Bjk)

where wk is the weight assigned to driver k (reflecting the relative importance of that root cause in driving correlated losses). The diagonal is set to 1 (a scenario is perfectly correlated with itself). The result is bounded to [0, 0.99] to prevent perfect cross-scenario correlation. This approach ensures that scenarios sharing many high-severity root causes receive high correlation, while unrelated scenarios receive near-zero correlation — without requiring historical loss data.

Step 3 — Portfolio aggregation (square-root-of-sum-of-squares)

Within each K-factor bucket, the diversified capital requirement is computed using the standard portfolio variance formula applied to the correlation matrix Σ:

Cdiversified = √( Σi Σj ci · cj · ρij ) = √( cT Σ c )

where ci is the standalone capital estimate for scenario i. This is the same aggregation formula used in market risk VaR models. The diversification benefit is the difference between the simple sum of standalone capitals (Pillar 1 approach) and this portfolio-diversified figure.

Step 4 — Market VaR (parametric, 99.5%)

Market risk is captured separately for each asset position using parametric VaR:

VaRi = Valuei × σdaily,i × √Ti × 2.576

where σdaily is the daily price volatility (%), T is the holding period in days, and 2.576 is the 99.5% one-tailed normal quantile. Across positions, a flat correlation ρ (adjustable via slider) is applied: VaRdiv = √(Σ VaRi² + 2ρ Σi<j VaRi·VaRj).

Step 5 — Counterparty CVaR (Vasicek single-factor model, 99.5%)

Counterparty credit risk is modelled using the Basel/Vasicek single systematic factor model, which underpins the IRB approach. The conditional default probability under the worst-case systematic factor realisation at confidence level α is:

CVaR = LGD × Φ( (Φ-1(PD) + √ρ · Φ-1(0.995)) / √(1−ρ) ) × Exposure

where PD is the probability of default, LGD is the loss given default, ρ is the asset correlation with the systematic factor (economy correlation), and Φ is the standard normal CDF. The 99.5% quantile (Φ-1(0.995) ≈ 2.576) sets the confidence level consistent with the scenario and market VaR approaches. CVaR figures are summed across counterparties (conservative — no inter-counterparty diversification credit is taken).

Step 6 — OFTR aggregation

The OFTR is the sum of: (a) the Pillar 1 floor — max(PMR, KFRP1, FOR); and (b) the total Pillar 2 add-on — the excess of scenario-diversified capital over the Pillar 1 KFR per K-factor, plus market VaR and counterparty CVaR. No diversification benefit is taken across K-factor buckets, consistent with MIFIDPRU 7.6.3R (no cross-K-factor offsetting). This is a conservative choice that recognises model uncertainty in cross-activity correlations.

4
Market Risk — Value at Risk Non-SNI
VaR at 99.5% confidence: Value × daily vol × √t × 2.576
Asset / positionCurrent size (£)Holding period (days) Daily volatility (%)VaR at 99.5% (£)
Total market VaR £0
Formula: VaR = Value × (vol/100) × √(holding days) × 2.576. Confidence level: 99.5% (factor 2.576). Assumes assets are perfectly correlated — apply a correlation adjustment below for diversification benefit.
VaR correlation adjustment (optional)
0% (fully diversified)100%100% (no diversification)
Diversified VaR
£0
Used in OFTR calculation
5
Counterparty Risk — CVaR Non-SNI
Expected loss (EL) and Credit VaR at 99.5% using Vasicek model
CounterpartyExposure (£)LGD (%) PD (%)Economy corr (%) EL (£)CVaR 99.5% (£)
Total £0 £0
CVaR (Vasicek): LGD × [N((N⁻¹(PD) − √ρ × N⁻¹(0.995)) / √(1−ρ)) ] × Exposure. Economy correlation capped at 24% per Basel framework.
6
Own Funds Threshold Requirement SNI & Non-SNI
OFTR = KFR (Pillar 1 + add-on) + FOR — Table 5 of the ICARA
Table 5 — OFTR breakdown
ComponentMiFIDPRU 4 (Pillar 1)Additional (Pillar 2)Total
OFTR = max(PMR, KFR, FOR) + scenario add-ons from K-factor aggregation + market VaR + counterparty CVaR. MIFIDPRU 7.6.3R prohibits offsetting between K-factors.
7
Overall Financial Adequacy SNI & Non-SNI
Available own funds vs OFTR, EWIs, headroom and winddown trigger
Available own funds & Early Warning Indicators
£
Table 6 — Threshold requirement and EWI
ItemMiFIDPRU 4AdditionalTotal / Status
Headroom analysis
8
Own Liquidity Threshold Assessment SNI & Non-SNI
Basic requirement (FOR/3), liquidity threshold (OFTR÷√12), stress scenarios and Table 8 factors
Available liquid assets (£)
£
Liquidity stress assessment narrative
Liquidity risk assessment — asset convertibility & restrictions
The firm must assess whether potential harms from insufficient liquidity apply to its business. The following findings should reflect the firm's actual position — edit as appropriate.
Unexpected payments — link between scenarios and liquidity requirement
The same severe but plausible scenarios that drive the OFTR also give rise to a liquidity requirement, through the possibility of unexpected payment obligations:
(a) Direct or indirect costs arising from litigation
(b) Redress payments to clients
(c) Regulatory fines or penalties
(d) Unexpected payments to maintain franchise, reputation or continued viability
Liquidity risk in significant business activities
Product pricing
Intra-day liquidity positions
Collateral management
Performance measurement & incentives
Table 8 — Factors impacting the available liquid assets (MIFIDPRU 7.8.7R)
# Factor Relevant? Potential impact
Per MIFIDPRU 7.8.7R. Assess each factor for relevance to the firm's business model and funding structure. "Yes" factors must be discussed in the liquidity narrative above.
9
Stress Testing & Reverse Stress Testing SNI & Non-SNI
Multi-year capital planning under adverse scenarios — forward-looking horizon beyond the 1-year VaR/CVaR
Stress testing assesses the firm's capital adequacy over a multi-year planning horizon (typically 3–5 years) under severe but plausible macro and firm-specific shocks. This is distinct from the 1-year 99.5% VaR/CVaR calculations — it tests whether the firm remains above OFTR throughout the economic cycle under stressed income projections.
Business lines / revenue streams
Table 7 — Stress testing results: net income projection (£)
Chart — Net income projection (£)
Reverse stress testing
Reverse stress testing works backwards — identify the point of failure first, then determine what combination of events would cause it. This differs from forward stress testing which starts from a plausible scenario and projects its impact.
10
Recovery & Wind-Down Planning SNI & Non-SNI
Linked capital ladder — EWI soft → EWI hard → wind-down trigger (FOR)
Capital ladder — live from Section 7 & 8 inputs
Recovery planning is activated when own funds fall below the EWI soft limit. Wind-down is initiated if funds reach the wind-down trigger (= FOR). Each stage has distinct governance obligations and FCA notification requirements.
⚠ Recovery planning (Appendix 1)
Triggered when own funds fall below the EWI soft limit. Recovery actions aim to restore capital above OFTR without initiating wind-down.
Recovery actions by EWI trigger
SOFT EWI BREACHED
HARD EWI BREACHED
✗ Wind-down planning (Appendix 2)
Triggered when own funds reach the wind-down trigger (= FOR). Recovery has failed or is not feasible. The firm must cease regulated activity in an orderly manner.
£
£
Wind-down timeline & costs
Total costs £0
Funds remaining £0
Wind-down actions & timeline
Month numbers are relative to wind-down trigger being hit.
11
Summary & Generate SNI & Non-SNI
Dashboard, completeness check, and document generation
ICARA summary dashboard
Completeness check

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MiFIDPRU 8 — Remuneration & Own Funds
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