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I. Introduction and Purpose

C 52/2017 STA Effective from 1/4/2021

1. All banks licensed by the Central Bank of the UAE must ensure that Pillar 1 risks - credit, market, and operational risk - are mitigated by capital, in compliance with the capital adequacy framework articulated in the document Central Bank “Regulations re Capital Adequacy” issued under Notice 60/2017 and the supporting capital standards and guidance, articulated in the document Central Bank “Standards and Guidance re Capital Adequacy of Banks in the UAE”. Incompliance with the Standards, each bank is required to quantify all risks that are not covered, or not sufficiently covered by Pillar 1 capital, and determine the additional capital required to mitigate these risks. The capital required to cover these risks is referred to as Pillar 2 capital.

2. Each bank is required to have a process to assess its overall capital adequacy as a function of its risk profile and its strategy. Each bank is required to maintain appropriate capital levels in accordance with the Central Bank Standards on Pillar 2 capital. This process is termed the Internal Capital Adequacy Assessment Process (ICAAP).

3. As part of the Supervisory Review and Evaluation Process (SREP), the Central Bank analyses the capitalisation levels of banks among other information, referring to the results of the ICAAP with regard to the internal view of capital adequacy. If the evaluation concludes that the capital levels of the individual bank are not satisfactory, the Central Bank may require a bank to meet an adjusted Minimum Capital Adequacy ratio accordingly.

4. Consequently, Pillar 2 is both a bank internal process reported under the ICAAP, and the evaluation of each bank’s compete capital adequacy includes the ICAAP in its regulatory process - the SREP. First, it is the responsibility of each bank to ensure that its ICAAP is comprehensive and proportionate to the nature, scale, and complexity of its activities. Each bank bears the responsibility for the appropriate identification, estimation, and reporting of risks, and the corresponding the calibration of capital necessary to mitigate these risks. Second, the ICAAP is a critical reference for supervision and for the supervisory dialogue between banks and Central Bank.

Purpose

5. This Guidance presents minimum expected practices to be considered by each bank in order to undertake their ICAAP, covering the process, content, outcome, and usage. It clarifies the application of the Central Bank’s expectations regarding the requirements of the Central Bank ICAAP Standards. Note, that the Central Bank plans to issue separately detailed requirements relating to the Internal Liquidity Adequacy Assessment Process (ILAAP).

6. It also intends to support each bank in the identification, measurement, reporting, and mitigation of Pillar 2 risks. This Guidance does not prescribe specific methodologies but rather, it provides a framework, within which a bank should elaborate research, analyse, and draw conclusions relevant to the risk profiles of their books. Each bank remains fully responsible for the methodology and process supporting the ICAAP.

7. All methodologies employed by a bank for its ICAAP should be relevant to its business model, risk profile, to the geographies of its exposures, and, in particular, to the features of the UAE economy. The methodologies and processes employed by the bank in its ICAAP should be fully documented, transparent and replicable. Each bank should be in a position to justify their decisions and modelling choices with historical data and benchmarking across a range of practices, which will be subject to supervisory scrutiny. Models employed for the measurement of Pillar 2 risks should comply with the Central Bank Model Management Standards and Guidance.

8. The Central Bank may apply proportionality for smaller and less complex banks when evaluating the ICAAP. This does not mean that smaller or less complex banks are exempted from the reporting requirements or from undertaking a comprehensive assessment of the risks they face. Smaller banks have to perform the whole ICAAP and address the full reporting scope. In cases where a bank’s capabilities lead them to use simpler methodologies, a more conservative capital treatment may be appropriate. However, the Central Bank expects a more sophisticated risk management approach from large banks and/ or banks with complex risk profiles in the assessment of their Pillar 2 risks.

9. For the licensed operations of foreign banks in the UAE, when this document refers to the bank’s Board, it should be comprehended as the Managing Director and/ or the highest committee in the UAE operations of the bank in which the Managing Director has to be the Chairman.

10. This Guidance serves several purposes. It

 
(i)Explains in more detail the Central Bank’s expectations on fulfilling the requirements of the ICAAP Capital Standards, in particular, related to the ICAAP (process) at each bank and certain aspects of the content of the ICAAP report;
(ii)Covers expectations on some processual elements of the ICAAP, such as an appropriate approval process of the ICAAP report and its submission timelines; and
(iii)Formulates expectations about additional sections of the ICAAP report (e.g. related to internal audit findings and changes compared to the previous ICAAP report).