Under the Pillar 3 rules in BIPRU 11, firms are required to disclose certain information on their capital requirements on at least an annual basis. Formal disclosure must be publicly available. Firms may publish their Pillar 3 disclosure in their annual accounts or in a separate document or medium. However, where a separate document is used, this must be clearly referenced in the accounts.
Pillar 3 sits alongside Pillar 1 (minimum capital requirements) and Pillar 2 (review process) which, together, provide firms with a group of disclosure requirements that allow market participants to assess information relating to a firm’s capital, risk exposures and risk assessment processes.
The firm may omit information it deems immaterial, in accordance with the rules. Materiality is based on the criterion that the omission or misstatement of any information would be likely to change or influence the decision of a reader relying on that information. Accordingly, where the firm has considered an item to be immaterial it has not been disclosed.
In addition, if the required information is deemed to be proprietary or confidential then the firm may take the decision to exclude it from the disclosure. In the firm’s view, proprietary information is that which, if it were shared, would undermine its competitive position. Information is considered to be confidential where there are obligations binding the firm to confidentiality with its customers, suppliers or counterparties. Where information is omitted for either of these reasons this is stated in the relevant section of the disclosure, along with the jurisdiction.
Client disclosures:
The following Complyport clients have used our web-facility to publicly list their pillar 3 disclosure:
