The client is the subsidiary of the largest private bank providing wealth management and investment banking services. It is a less significant institution subject to supervision from the local supervisor, the ACPR.
Noting the increasing implication of the local supervisor on ICAAP and ILAAP, the client requested Avantage Reply to perform a gap analysis of its existing set-up in light of supervisory expectations and market practices. Ultimately, the client sought clear recommendations to implement formal ICAAP and ILAAP processes, among other to pre-empt an anticipated increase in supervisory scrutiny.
Through a short timeframe, the work has been conducted in two phases: (i) an analysis of the existing setup with gap analysis; and (ii) establish a set of recommendations and the design of a roadmap.
To start, the team conducted a stocktaking exercise through a series of workshops and a review of documents (incl. the internal control report, risk report, recovery plan, etc.) to form an opinion on where the Bank stood compared to market practices. Then, the target state was defined through a combination of supervisory expectations (both local and European) and benchmarking on best practices. The identified gaps included: (i) the Material Risk Identification process, (ii) the risk appetite framework, (iii) the stress testing, and (iv) the embeddedness in the financial and liquidity planning processes of the bank.
In a short timeframe, the team delivers a report setting out its findings and associated recommendations. Those were translated into an action plan with timeline and allocation of tasks. Results of the analysis were presented to the Chief Risk Officer, and to the Deputy Chief Executive Officer.