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Compliance Officers Playbook

ECB Clarification: ICAAPs, ILAAPs, and Package Submissions

15 Feb 2025

Description

This European Central Bank (ECB) document clarifies supervisory expectations for banks' Internal Capital Adequacy Assessment Processes (ICAAPs) and Internal Liquidity Adequacy Assessment Processes (ILAAPs). It highlights governance expectations, focusing on continuous processes with strong internal controls and management body approval. The guidance covers forward-looking capital and liquidity assessments under normative and economic perspectives, stressing the need for credible scenario planning. Banks must demonstrate robust capital and liquidity management, including well-defined buffers and clear distribution policies. The document also specifies technical details for ICAAP/ILAAP information submissions to the ECB, requiring annual submissions of key documents and continuous updates of internal documentation. It emphasizes the importance of a clear Capital Adequacy Statement (CAS) and Liquidity Adequacy Statement (LAS) reflecting the management's perspective.

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