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This section would describe the extent of challenge and testing of the ICAAP. Accordingly, it would include the testing and control processes applied to the ICAAP models or calculations, and the senior management or board review and sign off procedures.
In making an overall assessment of a bank's capital needs, matters described below should be addressed:
i.
the inherent uncertainty in any modeling approach;
ii.
weaknesses in bank's risk management procedures, systems or controls;
iii.
the differences between regulatory capital and available capital;
iv.
the reliance placed on external consultants.
v.
An assessment made by an external reviewer or internal audit.
Internal control review
The bank should conduct periodic reviews of its risk management process to ensure its integrity, accuracy, and reasonableness. Areas that should be reviewed include:
•
Appropriateness of the bank’s capital assessment process given the nature, scope and complexity of its activities;
•
Identification of large exposures and risk concentrations;
•
Accuracy and completeness of data inputs into the bank’s assessment process;
•
Reasonableness and validity of scenarios used in the assessment process; and
•
Stress testing and analysis of assumptions and inputs.
