AIMA Fund Manager Briefing: The ICARA process – how best to approach it

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As FCA regulated entities continue to manage the implementation of the ‘Investment Firm Prudential Regime’ (IFPR), a significant challenge they’re facing is the preparation of the 'Internal Capital Adequacy and Risk Assessment' (ICARA) document.

The key change is the assessment of the ‘Overall Financial Adequacy Rule’ (OFAR), the calculation of the ‘own funds threshold requirement’ and the calculation of the ‘liquid assets threshold requirement’. The step by step process of undertaking the OFAR assessment is complex but essential. In this briefing we’ll focus on the practical aspects of the ICARA process specifically covering the following:

  • Content of the ICARA document
  • Assessment of risks and material harms
  • Wind down plan
  • Requirement for regulatory monitoring


  • Priya Mehta, Partner, Buzzacott


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