Prudential Regulation Authority Rulebook

4.1

This chapter sets out the PRA’s expectations for the content of the public disclosures required under Rule 4.1 of the rules.

4.2

The PRA expects a firm’s public disclosure to be a concise summary of its report on its assessment of its preparations for resolution. The PRA does not expect a firm’s public disclosure to include an overall judgement about whether or not the firm considers itself to be resolvable, or to contain unnecessarily detailed descriptions of particular resolvability arrangements or plans.

4.3

The PRA expects the information contained in a firm’s public disclosure to be consistent with the report submitted to the PRA under Chapter 3 of the rules. If a firm has chosen to include an executive summary or any similar introductory statement in its report, the PRA would not expect that summary or statement to constitute the public disclosure required under Rule 4.1.

4.4

The PRA expects a firm’s public disclosure to:

• Summarise its understanding of its resolution strategy and the steps the firm would take to facilitate resolution by the Bank relative to the stylised resolution timeline as described in Annexes 1 and 2 of the Bank’s Approach to Assessing Resolvability SoP. This should assist a user to understand how the resolution strategy of the firm works, what it means for its financial and operational counterparties, clients (including depositors) and investors.
• Describe the capabilities, resources and arrangements currently in place at the firm as referred to in paragraph 3.3 that have been implemented to improve its resolvability, including how these achieve the resolvability outcomes outlined in paragraph 2.3. The PRA also expects a firm to include a summary of its group structure, a summary of any testing it has carried out, and the governance processes it has in place for performing its assessment. The firm’s public disclosure should be designed to help users come to a view of the quality of the firm’s existing capabilities, resources and arrangements for resolution.
• Describe any outstanding steps that a firm is planning to undertake to remove or reduce any gaps in their capabilities, resources and arrangements for resolution. These should include an anticipated timeline for completion and details of the controls that exist in the firm to oversee its execution of these steps. The public disclosure should enable users to assess the feasibility and credibility of the firm’s plans for removing or reducing gaps in its capabilities, resources and arrangements for resolution. Users should also be able to assess how the firm’s financial and operational counterparties, clients and investors might be impacted over time as the firm implements its outstanding steps.
• Identify and describe any additional issues that could prevent these resolvability outcomes from being achieved. This should enable users to understand the other factors outside the firm’s control that could prevent the resolvability outcomes set out above in paragraph 2.3 from being achieved.

4.5

The PRA expects the firm to include in its public disclosure any material updates that have occurred during the period of time that has elapsed between submission of a firm’s report and publication of its public disclosure. This should ensure that users have up to date information on which to base decisions.

4.6

A firm may exclude information from the public disclosure on the grounds that it is proprietary or confidential. When excluding information on these grounds, the PRA expects a firm’s approach to be consistent with its approach to meeting its Pillar 3 disclosure requirements.⁸