Pillar 3 disclosure is not a new requirement. All investment firms and banks have had to publish their Pillar 3 disclosure for a number of years but for banks and some investment firms, changes are imminent.
Investment firms and banks are required to have a formal policy on how they comply with the disclosure requirements in the CRR/ FCA handbook and also to set out in a prescriptive way information that needs to be disclosed. However, given the public nature of the disclosure, it can be problematic to decide how much information a firm chooses to disclose especially around the sensitive areas of Pillar 2 capital and remuneration.
For the 2017 year end, some firms will have to use compulsory disclosure tables and templates. The frequency and amount of disclosure will apply on a sliding scale basis to each category of institutions. At the upper end of the scale, large institutions with listed securities will be required to provide some information on a semi-annual and quarterly basis, including a key prudential metrics table. At the lower end, small non-listed firms will only be required to make selected disclosures of governance, remuneration and risk management information and the key metrics table on an annual basis.
We can help you with all aspect of your Pillar 3 disclosure from drafting, review of specific templates and use of exemptions.