Monday, 9 April 2012

ICAAP vs ORSA - "Common Themes" from first attempts

As an addendum to the last doc, I found this rather cute list of observations from the FSA regarding the first sweep of ICAAP submissions. I like the fact that they exempted larger firms from what it ostensibly a bollocking for making so many omissions and errors, and I suspect something similar will be dished out in 2013 due to the lack of unequivocal ORSA guidance.

Of the 13 points, the errors in calculating Op Risk capital, advice to "keep it short" and the ticking-off for inadequate stress testing to be particulary amusing, but that doesn't detract from its usefulness for anyone with an ORSA to construct, even if it is as a "what not to do" list.

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