CySEC Advanced · Chapter 9 · Topic 11 of 13

Which risks does Pillar 1 only partly capture, and what triggers each?

The five risks that Pillar 1 does not fully capture (credit concentration, residual, securitisation, settlement and foreign exchange risk), what causes each and how a CIF should assess them.

By the ExamPass CY editorial teamLast reviewed 6 min read

Short answer

Five risks fall only partly within Pillar 1, so a CIF must assess them in its ICAAP. Credit concentration risk comes from one exposure, or a group of similar exposures, big enough to threaten core operations, often a few large counterparties, one large deal or one product; it is analysed for each legal entity and on a consolidated basis. Residual risk arises when credit risk mitigation underperforms. Securitisation risk requires understanding the underlying exposures. Settlement risk is a failure to deliver the asset or cash. Foreign exchange risk reaches beyond proprietary positions.

Risks only partly covered by Pillar 1

The fiveCredit concentration, residual, securitisation, settlement and foreign exchange risk
Credit concentrationOne exposure or a group of similar exposures (same borrower, region, industry or risk factor) that could cause losses large enough to threaten core operations or materially change the risk profile
Usual sources of concentrationLarge exposures to a few counterparties, one large transaction or reliance on one product
Level of analysisEach legal entity and the consolidated group
ResidualCollateral, guarantees or other mitigation that do not work as expected, such as unenforceable documents or a client payment collected late or not at all
SecuritisationThe arrangement fails, or the values and risks transferred do not emerge as expected; the firm must understand the underlying exposures' credit quality, risk characteristics and concentrations
SettlementAt settlement, one side fails to hand over the asset or the cash owed; most serious when the firm moves client funds
Foreign exchangeExchange-rate moves cause losses, which can be large in a liquid, volatile market; covers foreign-currency profit flows, client-driven deals and bad-debt provisions as well as proprietary positions

Source: CySEC Circular C026 (2012); Directive 2013/36/EU, Articles 80–82; Regulation (EU) 2019/2033, Articles 35–39.

Why are these risks only partly covered by Pillar 1?

Pillar 1 formulas treat exposures in a standard way, for example assuming a reasonably spread-out book and collateral that works as intended, so they can understate losses when reality differs. The exam material, following CySEC's 2012 ICAAP guidelines (Circular C026), names five risks of this kind that a CIF must assess and, where needed, cover with extra capital or controls. Since 5 November 2021, Class 2 CIFs have assessed their internal capital and liquid assets together under section 18 of Law 165(I)/2021, and Class 3 CIFs only if CySEC asks. This does not replace the ICAAP but widens it: the joint EBA and ESMA guidelines call the whole process the ICARAP, made up of an ICAAP for capital and an ILAAP for liquidity, and CySEC's January 2022 practical guide to the IFR and IFD calls it the ICAAP and ILAAP. Since 26 June 2021, the IFR has also charged Class 2 CIFs extra own funds (K-CON) on trading-book exposures above the concentration limit; see How are sovereign and public-sector exposures risk-weighted, and what are the large exposure limits?. The CRD's rules on managing residual, concentration and securitisation risk are covered in What processes must a CIF have for credit, market, liquidity, operational and leverage risk?.

Terms used in this note

Credit concentration
A single exposure or cluster of similar exposures large enough to threaten a firm's core operations or change its risk profile.
Credit risk mitigation
Techniques such as collateral, guarantees or netting that reduce the loss if a counterparty defaults.
Securitisation
A transaction that pools exposures and passes their credit risk to investors in tranches.
Settlement
The completion of a trade, when the asset and the cash change hands.

What causes concentration and residual risk?

A credit concentration arises from one exposure, or a cluster of similar exposures, for example to the same borrower, region, industry or other risk factor, that could cause losses large enough, relative to its earnings, capital, total assets or overall level of risk, to threaten its ability to keep its core operations going or to change its risk profile materially. Concentration risk is significant for most CIFs; it usually comes from large exposures to a few counterparties, one large transaction or reliance on a single product. Concentrations are analysed for each legal entity and for the group as a whole, because a concentration that looks small in the group figures can still threaten the subsidiary that holds it.

Residual risk arises when credit risk mitigation, such as collateral or guarantees, performs poorly or fails. Typical causes are ineffective documentation, which may make security impossible to enforce, and being unable to collect a client's payment on time, or at all. The protection existed on paper, but it did not reduce the loss as expected.

What drives securitisation, settlement and foreign exchange risk?

Securitisation risk is the effect on the firm's financial position if a securitisation arrangement fails, or if the values and risks transferred do not emerge as expected. A firm assessing a securitisation exposure must fully understand how creditworthy the exposures underneath the structured transaction are, what risks they carry, and any concentrations among them.

Settlement risk is the risk that, when a trade settles, the other side fails to hand over the asset or the cash it owes. It matters most when a firm transfers funds on behalf of clients: until both sides have completed, the firm can lose the asset it delivered or the cash it paid.

Foreign exchange risk means losses when exchange rates move. Because currency markets are highly liquid and volatile, the losses can be significant, so CIFs must identify, measure and manage the risk. It is not limited to proprietary positions: it also covers known profit flows in foreign currencies, transactions driven by clients, and bad-debt provisions in foreign currencies.

How to think about it

For each of the five, ask what went differently from the standard picture. Concentration: the book was not spread out. Residual: the collateral or guarantee did not work. Securitisation: the structure did not behave as expected, so look through to the exposures underneath. Settlement: one side did not deliver. Foreign exchange: currency moves hit more than the trading positions, reaching profits, client flows and provisions too.

Common mistakes

  1. Assuming Pillar 1 capital covers everything. Its formulas only partly capture concentrations, failed mitigation, complex structures and wider currency flows, so the ICAAP must add capital or controls.

  2. Relying on collateral without checking the documents. Ineffective documentation is a classic source of residual risk.

  3. Assessing a securitisation by its structure alone. What matters is the quality and risk of the exposures underneath, including concentrations.

  4. Treating settlement as a back-office formality. Until both sides complete, the firm can lose the asset or the cash, especially when moving client funds.

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Last reviewed on by the ExamPass CY editorial team against the law in force on that date. Study notes help you prepare for the CySEC exams; they are not legal advice. ExamPass CY is not affiliated with CySEC.

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