Explanatory Note 2014 on the Establishment of Recovery Plans

Transcription

1 Explanatory Note 2014 on the Establishment of Recovery Plans

2 Explanatory Note 2014 on the Establishment of Recovery Plans Background The Explanatory Note for drafting a bank recovery plan (including the attached data template) is meant to assist in the preparation of the recovery plan to be provided by a bank under BIRG (Bankeninterventions und restruktruierungsgesetz; Austrian Banking Intervention and Restructuring Act). The Explanatory Note in no way alters the bank s responsibility to fulfil all legal requirements under the BIRG, in particular, the information required by BIRG is not restricted by this Explanatory Note. In case the institution is obliged to set up a group wide recovery plan, BIRG requires plans for the recovery of the group as a whole, the top level institution and every major subsidiary in Austria. Please note that this Explanatory Note only covers the recovery plan for the group as a whole. This Explanatory Note is accompanied by seven Excel templates that should be filled in with the relevant information. These templates serve the purpose to support the recovery plan. For ease of preparing the recovery plan, the Word document and the Excel templates are provided separately. Credit institutions ought to provide a concise yet exhaustive final document in pdf file format which includes all policies and process descriptions together with the relevant Excel templates. In addition to the comprehensive document, the completed Excel templates should be submitted separately as well. The scope and degree of detail of the provided documents should be commensurate with the complexity and scope of business of the specific credit institution. 1

3 Group Recovery Plan In case the credit institution is obliged to implement a group-wide recovery plan according to Art. 7 BIRG the submitted documents must comprise the respective plans for the group 1, the top level institution and for all major subsidiaries in Austria. The aforementioned plans may be set up in one single document comprising those aspects which apply to all entities in the same manner as well as dedicated chapters outlining the specifics on each organisational level. 1 For the purpose of this document the notion group is used in accordance with Art. 3 nr. 4 BIRG, thus signifying a group of credit institutions according to Art. 30 Austrian Banking Act (BWG), a network of credit institutions according to Art. 30a BWG or an Institutional Protection Scheme according to Art. 113 nr. 7 of Regulation (EU) No 575/

4 Table of contents 1 Executive Summary Internal governance Strategic Analysis Business activities and overall structure of the institution Financial and legal structure and intra-group interlinkages Recovery options General overview of recovery options Assumptions and scenarios Recovery indicators and escalation process Specific recovery options Communication and disclosure plan Information management Preparatory measures and ongoing improvement of recovery plan Appendix Documents to be submitted Concluding remarks Contact List of abbreviations

5 1 Executive Summary In this section, the institution is expected to summarize the main elements and conclusions of its recovery plan. The summary should be accompanied by/given as a PowerPoint presentation on the main elements of the recovery plan that can be used for focused presentations to senior management and supervisors. The summary should include at least the following elements: the key elements and main insights presented in the different sections of the plan and a summary of overall recovery capacity a summary of any material changes to the institution or the recovery plan since the last update of the recovery plan, if applicable, in particular: o Acquisitions/divestitures of material businesses/entities o Major changes in the internal and external interlinkages o Major changes in stress scenarios and the underlying assumptions o Major changes in recovery options o Major changes in potential obstacles The development of the recovery indicators since the last update of the recovery plan. Quantitative indicators may be provided in a separate Excel table including data on their development since last year (if available). a summary of the communication plan a general overview of organizational and procedural steps that need to be undertaken for the preparation and implementation of the plan, including a time schedule and responsibilities. 4

6 2 Internal governance This section should include a description of internal governance with regard to the design of the recovery plan, the approval process and the governance process in case it needs to be implemented in a crisis situation. This section should at least provide a description of: how the plan was developed: including the identification and functions of persons responsible for preparing, implementing and updating the different sections of the plan (in the group and the individual legal entities). In particular, the section should entail a description of personal responsibilities for keeping the recovery plan up-to-date as well as a description of the process in case the recovery plan needs to be updated to respond to material changes affecting the institution or the group or their environment. Contact details of responsible staff members should be provided in the Appendix; a description of how the plan is integrated and incorporated in the corporate governance framework and the overall risk management framework of the group taking into account the risk appetite of the group and potential links with the stress testing framework of the group. This section should highlight the risk management framework that is currently implemented in the bank as well as the processes and responsibilities for liquidity and capital management. In particular, it should highlight the connection of the ICAAP and the internal contingency plans (e.g. contingency funding plan) with the recovery plan. Furthermore the assignment of responsibilities throughout legal entities of the group and the role of central oversight functions ought to be highlighted. In case the credit institution is embedded into a de-centralized sector structure, sector-wide responsibilities and the assignment of duties to sector-wide coordination bodies and committees should be elaborated as well. Typical organizational units that are expected to be involved in the establishment of a recovery plan are Risk, Strategy, Operations, Treasury, Finance, individual business lines, Legal, Participation Management, Compliance, Internal Audit and other units for selected parts (e.g., Macroeconomic Research for the scenarios or Regulatory Affairs and External Affairs for the communication plan); 5

7 a description of the measures and arrangements taken within the group to ensure the coordination and consistency of the group and individual recovery measures; by whom the current version of the plan was approved: including the involvement of senior management, the supervisory board respectively its risk committee, whether the plan was presented to the internal and/or external auditor and/or the risk committee. A confirmation should be provided by the group stating that the recovery plan has been approved by the management body of the institution; the approval of the management body of significant subsidiaries if necessary to implement the recovery plan; the conditions and procedures necessary to ensure the timely implementation of recovery options in a crisis situation: the document needs to explain how the escalation and decision-making process is designed. It should also clearly describe the decision making process with regard to the activation of the plan (i.e., when triggers are met). This includes a discussion of the roles involved in this process, in which conditions the plan will be activated, the procedures that need to be followed and the criteria that will determine which option will be implemented. The plan should also highlight the differences between the governance in a crisis situation vs a normal operating environment (e.g., the establishment of a recovery committee that in crisis situations takes over responsibilities of the institutions risk committee). The section should be supplemented by an organizational chart of the group and legal entities up to the relevant levels for the development and the approval of the plan (typically at least the board and the first two levels of the organization). 6

8 3 Strategic Analysis The strategic analysis needs to contain a summary of the structure of the institution, the core business lines, critical functions and the internal and external interlinkage of the institution. The strategic analysis needs to allow the judgement of the applicability of the general and specific recovery options in the recovery plan. Moreover, the strategic analysis will be the basis for the establishment of a resolution plan. 3.1 Business activities and overall structure of the institution The institution needs to lay down a description of its overall global business and risk strategy, and its business model and business plan, including a list of all jurisdictions in which it is active through the major subsidiaries, branches and special purpose entities (including leasing entities). Where appropriate, the details on the major subsidiaries should be provided in an Excel template to allow for easy comparison. The institution needs to show a general overview of its legal structure (including material subsidiaries and branches), its key business lines and critical functions and a mapping of core business lines and critical functions to legal entities and material branches. This overview should focus on the material branches or legal entities including the rationale (process and metrics) why they are considered as material. In the context of this Explanatory Note, for the materiality of branches or legal entities please refer to Bankeninterventions- und restrukturierungsgesetz- Verordnung of 2 nd January This section should comprise a list of market sectors (defined by topic as well as by geography) in which the credit institution or its related entities play a substantial role (or where it is planned that they will play a substantial role in the future). Hereby the term substantial role both applies to the relevance of a certain business area for the institution itself as well as to the relevance, the institution s business activities have for the financial market from a macro- 2 Verordnung der Finanzmarktaufsichtsbehörde (FMA) zur Festlegung der Kriterien für die Wesentlichkeit nachgeordneter, zugeordneter oder teilnehmender Institute für die Zwecke des Bankeninterventions- und -restrukturierungsgesetzes (Bankeninterventions- und restrukturierungsgesetz-verordnung - BIRG-V). BGBl. II Nr. 2/

9 prudential perspective (on local / regional / European level). 3 Moreover, this section should highlight risk concentrations. The section should include an organizational chart showing core business lines and a mapping to legal entities as well as a breakdown of FTEs by business unit. 3.2 Financial and legal structure and intra-group interlinkages The section should show the financial structures for the institution and the main entities (with a breakdown of turnover, cash flows, liquid assets, funding needs, large exposures, P&L, RWAs, Common Equity Tier-1 capital and Total Capital by legal entity). This breakdown should be given for those entities that are marked as material by the institution according to Template 1 that accompanies this document. Furthermore a detailed description of the methodology used to assess the value and the marketability of the main assets and core business function should be given. The institution has to show the internal interlinkages of the entities of the institution with respect to the material branches or legal entities. This includes economic, legal, organisational and operational connections among entities and between the parent company and the individual entities: Economic interlinkages include all existing material intra-group exposures and funding relationships as well as the capital allocation and liquidity flows within the group, intragroup guarantees that are in place and intra-group guarantees that are expected to be in place when recovery action is required. Moreover, it should include a description of any existing intra-group financial support agreements including the parties to the agreement, 3 An example for business operations with a substantial macroeconomic relevance would be if the institution or a subsidiary is the principal market- maker for sovereign issuances in a certain country. 8

10 the form of the financial support and the conditions associated with the provision of the financial support. Parent company: Legal interlinkages include in particular the description of contracts between entities (e.g., the existence of domination agreements, profit and loss transfer agreements, tax dependencies between the entities). The description of organisational and operational interlinkages should highlight in particular the main services that are supplied by one entity to another or to the group as a whole. Examples include IT or central functions such as Treasury services (including liquidity and capital management and access to financial markets), transaction services, internal audit, risk controlling, legal, HR or certain back office functions. Moreover, the institution should depict its relevant external interlinkages in order to allow an assessment of contagion risk in the financial system. In particular this involves information on a description of significant exposures and liabilities to main counterparties; a description of significant financial products and services which are provided by the institution or the group for other financial market participants; the relevant contract partners for assets and liabilities (banks and non-banks); please provide also information on your criteria for determining the relevant contract partners; the relevant services that are conducted for third parties (external parties and within the group) respectively that third parties conduct for the institution (outsourcing). Examples entail IT, transaction services, clearing, workout and custody services; implicit support to third parties (e.g. SLA). The goal of this analysis is to (i) identify potential contagion risks within the financial system and to (ii) provide the background for evaluating the recovery options. 9

11 4 Recovery options The objective of a recovery plan is not to forecast the factors which could prompt a crisis but rather to assess if options available to counter a crisis are sufficiently robust and if their nature is sufficiently varied to face a wide range of shocks of different natures. Consistently with this objective this chapter aims to provide a "menu of options" which consists of a range of possible recovery options to respond to financial stress, whether idiosyncratic or systemic, and to assess their feasibility and impact. We expect at least the following information to be provided in this section: 4.1 General overview of recovery options The purpose of this section is to give a description of all recovery options that could be available and the actions that would be taken to enable the early execution of such options (i.e. when recovery indicators materialise). The recovery options are not business-as-usual measures but should be extraordinary in nature. Later in the document, it will be assessed the extent to which these recovery options could be implemented in different scenarios/assumptions. The plan should list the rules and measures to ensure emergency access to alternative sources of funding, including potential sources for liquidity and an assessment of potentially available collateral. It should also provide a valuation of the securities that the institution has access to and lay out the possibilities for liquidity transfer between different entities to ensure that it can carry on its operations and meet its obligations as they fall due; these measures should include external measures and, where appropriate, measures that aim at reorganising the available liquidity within the group; the institution should highlight, if the recovery plan contains any liquidity-related measures which deviate from the institution s official contingency funding plan (CFP). If such discrepancies exist, the institution should provide the respective reasoning; 10

12 maintain and restore the capital position of the institution (e.g., via external or internal measures); reduce risk and leverage, or to restructure business lines including, where appropriate, an analysis of all possible material divestments of assets, legal entities, or business lines; restructure the group s liabilities on a volunteering basis without triggering an event of default, termination, or similar event; restructure individual business lines and entities; ensure the continuation of the business operations, including access to financial markets, infrastructure and IT services. Moreover, it should entail a listing of measures to facilitate the sale of assets and/or businesses in a reasonable time frame and for a reasonable cost; other management measures or strategies to restore financial solidity (including the expected financial implications and cost of these measures and strategies); preparatory measures that the institution took or intends to take in order to facilitate the implementation of the recovery plan; including those necessary to enable the timely recapitalisation of the institution (i.e. the remediation plan); For each recovery option identified, the institution is expected to describe the measure in a general way and to identify the possible obstacles to its implementation including consideration of impact on the rest of the group, customers and counterparties. For each recovery option the institution should continuously evaluate the estimated impact (e.g. amount of capital or liquidity) of implementing the measures as well as the necessary time frame. These quantitative aspects ought to be part of the list of recovery options (see the templates that accompany this Explanatory Note). Those options for which a well-founded estimate of size and time frame may not be obtained should be highlighted accordingly. In addition, the institution is expected to provide the following analyses for each option: 11

13 Impact assessment of the recovery options comprising at least an assessment of the: o financial and operational impact: The impact should be tentatively assessed both in a normal situation and in the different stress scenarios (please refer also to section 4.2 Assumptions and Scenarios). For each option, the plan should in particular assess the impact on Capital differentiated by the different types of capital: Common equity tier 1 capital, additional tier 1 capital, tier 2 capital, available financial ressources (according to Pillar 2 of the Basel framework) Liquidity by different maturities Profitability RWAs Assets Maintenance of business operations Where relevant, the plan should clearly identify the different entities of the group which may be affected by the option or involved in its implementation. This section should - where applicable - include a detailed description of the methodology used to assess the value and the marketability of the recovery options (e.g., of core businesses, operations and assets). o external impact: the impact foreseen on critical or systemically relevant functions performed by the institution as well as the impact on other market participants (such as customers, employees, counterparties, shareholders, stakeholders and society at large) The impact assessment should clearly mention the valuation assumptions and all other assumptions made, concerning inter alia the marketability of assets or the behaviour of other financial institutions. In particular, the impact assessment should include a detailed description of the processes for determining the value and marketability of the core business lines, operations and assets of the institution. 12

14 Risk assessment: for each option, the institution is expected to make an analysis of the risk associated with it. This includes both the risks that the option cannot be implemented (feasibility) and the risk resulting from its implementation (systemic consequences): o Feasibility: the institution should provide for each recovery option answers to the following topics: The estimated success rate on a scale, and the rationale. Where appropriate, the success rate should also be differentiated between the scenarios. Factors that could reduce its effectiveness (up to the point of making it impossible to implement the option) and potential ways to mitigate them. These factors should at least consider legal, operational, business, financial, and reputational risks (including where appropriate any risk of rating downgrades). In a group recovery plan an analysis of potential obstacles to the effective implementation of each recovery option which result from the structure of the group or intra-group arrangements, including where appropriate whether there are substantial practical or legal obstacles to the prompt transfer of own funds or the repayment of liabilities or assets within the group. The internal process in case the option needs to be implemented, including the steps to be followed, the timing, necessary decisions and parties involved, up to the point of implementing the option. If the timing is uncertain, estimated ranges may be provided, together with reference to factors that would affect these ranges. Preparatory measures to increase the probability of success for specific measures. 13

15 The bank is also invited to discuss its potential past experience in executing such an option or similar ones. o Systemic consequences: the institution should identify any potential system-wide implications associated with the implementation of the option, as well as its impact on any future resolution in case recovery options would not be effective. When substantial obstacles or hurdles have been identified, the institution should outline solutions for overcoming these potential problems. Operational plan: for each recovery option, the institution should attach an operational plan (e.g. internal manuals/guidelines) which explains how the continuity of operations can be maintained in a recovery phase, if the recovery option is implemented. The plan should include at least an analysis of internal operations (for example information technology systems, suppliers and HR operations) and the institution or group s access to market infrastructure (i.e. clearing and settlement facilities, and payment systems). In particular, the operational contingency plan should include: o any arrangements and measures necessary to maintain continuous access to relevant financial markets infrastructures; where the option involves the separation of an entity from the group a demonstration how the separated entity can continue to operate without any group support; o any arrangements and measures necessary to maintain the continuous functioning of the institution's or the group's operational processes, including infrastructure and IT services; The section should be supplemented by Template 4 and 5, showing for the individual resolution options the process, (corridors for the) impact, time to implement, time to effectiveness and potential obstacles in implementation. Moreover, the section should also list those recovery options that had been considered but rejected together with the rationale for their rejection. 14

16 4.2 Assumptions and scenarios The objective of this section is for the institution to define several stress scenarios and tentatively assess their potential impact. The objective of this section is not to identify the next crisis but, rather, to define a set of scenarios under which the efficiency of the different recovery options will be assessed. The institution is expected to specify several scenarios which should cover at least the following types of financial stress (in each case, the institution is required to differentiate slowly and fast moving financial stress of different severities): Idiosyncratic shock (individual institution and group wide) Systemic shock A combination of the above The scenarios should reflect the relevant substantial risks for the institution and explain in detail the used assumptions. In particular, the institution should lay out the connection of scenarios with the scenarios that are used for internal stress tests as part of the ICAAP (including the responsibilities on deciding on the scenarios and working out the details in their modelling). Each of the scenarios considered should be severe enough to have a serious, negative impact on the institution. The institution should choose scenarios judged to be relevant for triggering the status being in recovery mode and believed to be sufficiently likely to occur. The institution is expected to tentatively assess the impact on each of these scenarios on solvency, liquidity (short term), funding (medium to long term), profitability, and operations of main entities, businesses, etc., identified in the organisational description. This section should be supplemented by Template 6 which gives a narrative description of the scenarios and shows their impact on the institution s key parameters over time. 15

17 4.3 Recovery indicators and escalation process Recovery indicators determine the moment in time when an institution starts to consider and determine which specific recovery option (if any) it may need to apply in reaction to the actual situation that has materialised. Since each crisis is different, recovery indicators do not automatically activate a specific recovery option but rather an early identification of the best way forward with the recovery plan. They should not be understood as thresholds leading to a compulsory pre-identified reaction but rather as the point in time at which the efficiency of the different recovery options is reassessed and their potential implementation envisaged. As such, they need to be calibrated to give sufficient lead time to the institution for preparing and implementing the recovery options to counter the crisis situation. In particular, the recovery indicators are expected not only to assess stock quantities (such as capital ratios) but also to consider changes over time and expectations of future developments. Recovery indicators are thus a key part of the escalation and decision-making process. The institution should also provide in this part of the recovery plan detailed information on how the recovery indicators are incorporated into the institution s overall risk management frameworks and how the recovery indicators are aligned with existing liquidity or capital contingency plan triggers as well as with its risk appetite framework. The institution is expected to specify these specific recovery indicators (including examples and metrics), in particular, the institution should determine quantitative and qualitative recovery indicators (including pillar I and pillar II indicators): relating to its solvency position (capital and RWAs) relating to its liquidity situation relating to qualitative indicators (e.g. Expert Calls ) relating to the stress scenarios (see next section) and the deterioration of the conditions in which it operates The institution needs to define an escalation and information process to ensure that senior management is comprehensively and timely involved into decision making. Decisions made as 16

18 part of this need to be documented. The supervisory board needs to be involved as appropriate and also the supervisory authorities need to be informed comprehensively and timely. In any case, the institution should inform the supervisory authorities annually (as part of the update of the recovery plan) on the current status of the recovery indicators. The section should be supplemented by Template 7 that lists the Recovery indicators, shows the current values of the indicators and indicates amber/red thresholds for them. Moreover, the section should entail a description of the risk appetite and describe the rationale for choosing the specific values of the thresholds. For each recovery indicator, it should show the decisions and escalation processes to be triggered by amber/red indicators. 4.4 Specific recovery options For all scenarios, the institution needs to determine the adequate recovery options and describe them in the recovery plan. While in the section above, all recovery options are assessed individually without relation to individual scenarios, this section focuses on the analysis of the recovery options in relation to individual scenarios. The institution should therefore examine which recovery options could be applicable in a specific scenario. This assessment should comprise the potential impact of the recovery options, their feasibility, including the potential obstacles to their implementation and the timeframe required for their implementation. On the basis of this test, the institution or the parent undertaking of the group should assess its overall recovery capacity, which is the extent to which the recovery options allow the institution or the group to recover in a range of severe stress situations. Most likely every option shows different results regarding the specific scenario taken place. The section should be supplemented by two templates: Template 8 shows the specific adaptations (if any) that need to be made for each option regarding the individual scenario. The template needs to be filled in for each scenario separately. Template 9 shows for every chosen scenario the recovery options that tentatively would be implemented in that scenario and their combined impact over time. Main question is: are the chosen options able to remedy the crisis situation? Please use one template for each scenario. Template 9 is structured as follows: the 17

19 first set should display the impacts on the mentioned indicators/ratios over the next 3 years for each of the individual scenarios (essentially a copy and paste from the previously filled templates 4 on the scenario impact). Within the second set the institution should indicate, in which year the chosen recovery options (according to Template 4) for each of the respective individual scenarios should be initiated (e.g. by ticking the box for the first, second or third year). The impacts of the chosen recovery options within the indicated time frame on each of the scenarios should be demonstrated on the third data set of Template 9. 18

20 5 Communication and disclosure plan The institution is expected to provide a detailed internal and rough external communication plan highlighting the most relevant actions, as well as an analysis of how this communication plan can be implemented in a recovery phase and for each of the different recovery options, providing an assessment of the potential impact on the business and on financial stability in general. This communication plan should address both: Internal communication to senior management, staff, etc. In particular, the internal communication plan should entail a plan on the upfront communication to entities that are particularly affected by the recovery options (e.g. communication with entities that could be sold off). External communication towards shareholders, customers, supervisory authorities, counterparties, financial markets/investors, market infrastructures, depositors and the public generally, as appropriate. The recovery plan should include an analysis of how the communication and disclosure plan would be implemented in a recovery phase for each recovery option, providing an assessment of the potential impact on the business and on financial stability in general. Where relevant, the recovery plan should also explain, how potential additional capacity is to be established (e.g. call centers). 19

21 6 Information management The institution should describe how the group ensures that the right information is available within a short time frame for decision-making in a stress situation. A specific analysis is required for each recovery option in which the institution should define the information needs specific to this option and should demonstrate its capacity to deliver the necessary information. In addition, the bank should also describe how it can provide, in a crisis situation, in a timely manner, the information that is necessary for authorities to assess the situation. Such information includes for example: actual intra-group exposures through intra-group guarantees and loans; actual trades booked on a back-to-back basis; actual amounts of liquid assets in the parent bank and subsidiaries; off-balance sheet activities; the bank's actual largest exposures towards other financial institutions as well as corporations. Possible information provision issues: data sources data quality assurance automatic vs. manual interfaces the processes needed to fill the data into the systems 20

22 7 Preparatory measures and ongoing improvement of recovery plan The plan should include a list of all preparatory measures that the institution has taken or plans to take in order to facilitate the implementation of the recovery plan or improve its effectiveness, including those necessary to enable the timely recapitalisation of the institution and to overcome obstacles to the effective implementation. It should summarize the gaps that have been identified during the establishment of the plan and outline the steps (including a time schedule) that the institution takes to remediate these gaps/make the necessary preparations. The plan needs to be aligned with the according organizational units. Examples of preparatory measures include early preparation of decisions by relevant decision bodies (management board, board of supervisors) in order to implement specific recovery options (e.g. capital increases) without significant delays; preparatory measures to facilitate the sale of assets or business lines in a timeframe appropriate for the restoration of financial soundness; early provision of resources (personnel, IT-resources including data sources and information processes, ); remediation of shortcomings in processes, governance frameworks and organizational structures, trainings, etc. Moreover, this section should describe how the institution intends to update the group plan: this includes a description of who is responsible for keeping the plan up-to-date, the frequency with which the plan will be updated, and a description of the process in case the plan needs to be updated to respond to material changes affecting the institution or its environment. 21

23 8 Appendix 8.1 Documents to be submitted The recovery plan should be supplemented by all relevant documents that the recovery plan refers to (e.g. internal policies, guidelines, process descriptions, ) as well as the provided Excel templates. The key elements of the recovery plan should be summarized in a concise PowerPoint presentation that can be used for decision making by senior management (~20-30 pages). The remediation plan should be given in an appropriate format (Excel) including steps, responsibilities, timing and dependencies between the individual steps. The appendix should include a list of telephone numbers (also mobile) of responsible persons that can be contacted for further follow-up questions in connection with the recovery plan. 8.2 Concluding remarks Sources of information as of YE 2013: BIRG as of July 31, 2013, Bundesgesetzblatt I Nr. 160/2013 BRRD (please check latest version) EBA Consultation Paper on the content of recovery plans as of 11 March Contact Pls refer with any questions to Reocvery-Plan@oenb.at and to the SPOC of your bank. 22

24 8.4 List of abbreviations This section provides a list of abbreviations in the order in which they appear in the text: BIRG Bankeninterventions und restruktruierungsgesetz BRRD Bank Recovery and Resolution Directive BWG Bankwesengesetz CFP Contingency Funding Plan ECB European Central Bank FTE Full Time Equivalent HR Human Ressources ICAAP Internal Capital Adequacy Assessment Process IT Information Technology OeNB Oesterreichische Nationalbank P&L Profit and Loss RP Recovery Plan RWA Risk Weighted Asset SLA Service Level Agreement 23