Wind Down Planning

White Paper

A Practical Guide to Wind Down Planning

Wind-Down Planning remains high on the agenda of the Financial Conduct Authority (FCA). The first part of this paper describes the WDP in more detail, summarising its purpose, differences to other regulatory requirements, and what information should a plan include for it to be compliant. The following section lays out practical considerations on the four key themes that firms should scrutinise when improving their WDP.

Case Study

Recovery Fire Plan Drill

A UK challenger bank, providing a range of services to both individuals and business clients, engaged Avantage Reply to assist with the preparation for the Recovery Plan Fire Drill exercise, in line with the Prudential Regulation Authority’s (PRA) expectations and to provide independent feedback on the exercise conducted.

Briefing Note

Transforming Data Collection from the UK Financial Sector

In February 2021, the Bank of England (BoE) published its plan for transforming data collection from the UK financial sector. Learn more about the BoE’s vision, key proposed reforms, the transformation programme timeline, and how Avantage Reply can help businesses along this journey.

Capital Management

Briefing Note

Capital Planning Tool - Forecasting Capabilities for Solvency Ratios

Leveraging on its experience and in line with market practices, Avantage Reply has developed a Capital planning tool. Flexible and easy to use, it provides financial institutions with a tactical tool which allows them to easily perform capital simulations under different scenarios and integrate key outcomes into capital management and decision-making processes.

Risk Management

Briefing Note

The IRB Supervisory Formula and Estimation Risk

The PRA has previously expressed concerns regarding potential errors stemming from the internal model estimation process within credit risk, calling for Margin of Conservatism (MoC) to cover for possible underestimation. We have summarised the approach explored by the EBA to account for this possible underestimation.

Case Study

Identification of Financial Risks Associated to Climate Change

Avantage Reply supported a UK subsidiary of an Asian G-SIB that provides services to both retail and corporate customers to ensure all of its financial risks associated with climate change are identified and managed appropriately across its businesses.

Case Study

Review of Stress Test Methodology for Financial Risks Associated to Climate Change

Avantage Reply assisted a UK subsidiary of an Asian G-SIB with an independent review of its stress-testing methodology for financial risks arising from climate change.

Credit Risk Management

Briefing Note

New Trends In Credit Risk Management: Real-Time Analysis And Data Teams

In Credit Risk management, it is common practice for banks to use financials for assessing the creditworthiness of large and mid-corporates, with the drawback of being outdated by the time the credit review takes place. This paper proposes the use of real-time transactional data to circumvent this issue. This process can be further improved by setting in place teams dedicated to data management and preparation with the benefit of centralising the information used for other purposes, e.g. modelling, loss collection, monitoring, validation.

Reputational Risk

White Paper

Reputational Risk for Financial Institutions: The Quantitative Approach

Avantage Reply has designed a quantitative model for the assessment of Reputational Risk, traditionally considered as discretionary, subjective and highly prone to interpretation. The Reputational Risk Quantitative Model allows us to overcome the reliance on human sensitivity for risk management. Download our white paper to find out more about the Q-model.

Case Study


A leading trade association for the UK banking and financial services sector was looking to respond to one of the UK government bodies’ call for evidence on regulatory coordination in respect of recommendations for improving Cost/Benefit Analysis (CBA) by financial-services regulators in the UK. Avantage Reply was able to finalise the policy paper for the client to successfully submit their response to the UK regulator within the required timeframe.

UK Finance

White Paper

Financial Services Future Regulatory Framework Review: Phase-II Consultation 2

The FRF review is a major opportunity to improve the effectiveness and efficiency of banking and finance regulation now that the UK can determine its regime according to its own priorities. In this response to HMT’s first consultation on phase II of the review, we make detailed proposals for updating the framework under five main headings.

Case Study

Operational Risk Scenarios and Stress Testing

Avantage Reply assisted a UK asset manager that provides services to both retail and institutional clients, in ensuring its operational risk framework and stress testing approach meet the regulatory requirements and are aligned with the industry best practice.

Case Study

Transition to direct supervision by the European Central Bank

The ECB banking supervision is based on the same rules as local supervision (single rulebook), public information on the differences between both is not commonly available. While there are differences, these are on a practical level and only known to experts with insights on both locally and directly supervised banks. Avantage Reply prepared a review of these differences and the gaps of the client to these the previous year. The client wanted to have an update on these recommendations based on the progress that was made during the year, also with regard to the updated timeline to ECB supervision. To address these topics, Avantage Reply organised workshops with its subject matter experts and the client and reviewed the relevant documents provided by the client.

Case Study


Avantage Reply assisted a client that was reviewing a potential transaction as part of a strategy to take on selected exposures to second charge mortgages and efficiently deploy its capital resources. As part of its broader review, the client asked Avantage Reply to review their internal materials, identify relevant considerations (primarily from a capital and liquidity perspective) and provide an evaluation of the proposed structure of the transaction.

Case Study


An EU bank had established a UK subsidiary to continue the activities of their currently passported branch after Brexit. The goal of the project was to assist the client with developing documentation that aligned with internal expectations and regulatory requirements in the UK. Avantage Reply reviewed the risk management framework documentation for the subsidiary and four key documents for the subsidiary in the UK based on FCA regulation.

Case Study

Regulatory Reporting of a UK Branch, EU Bank

Avantage Reply assisted the UK branch of an EU bank who was expanding its UK activities in deposit-taking and commercial mortgages. The goal of the project was to assist the client with its regulatory reporting and compliance in the UK. Avantage Reply reviewed the reporting requirements for the branch and developed a comprehensive suite of all reports that branches in the UK need to review and assess.

Climate Risk

Briefing Note

Environment & Climate Risk RMF Self-assessment

Leveraging on ECB Guide on climate-related and environmental risks and emerging market practices, Avantage Reply has developed a self-assessment tool for financial institutions. The key objective is to help financial institutions while engaging bilateral discussions with ECB early 2021 and evaluating internal capabilities in terms of Environment and Climate-related risk management framework. Interactive and practical, the self-assessment tool covers the key building blocks of ERM function and assesses an institution’s readiness and preparedness in identifying, measuring and managing climate-related risks. Integration of climate dimensions at the highest level of the organization is key due to the transversal impact of climate risk over credit, market, liquidity, operational and other transversal risks.

Stress Testing

Briefing Note

Impact of COVID-19 on Stress Test Models

Since the 2008 financial crisis, regulators have emphasised the importance for banks of using stress tests to better identify potential weaknesses in their banking books, trading books and liquidity positions in the event of market turmoil. This paper will show model outcomes likely to be observed by banks in the 2021 STEBA and propose solutions and considerations for banks to mitigate the risk of having to deal with unrealistic model outcomes.


Briefing Note

Supervisory Expectations for International Banks in the UK

On 11 January 2021, the Prudential Regulation Authority (PRA) published a set of documents to outline its approach to international banks (including designated investment firms) operating in the UK, covering both subsidiary and branch structures. This was expected. Our briefing note summarises the key proposals and outlines what they mean for international banks.


Briefing Note

ICAAP quantitative tools

Leveraging on its experience and in line with market practices, Avantage Reply has developed several assets for the ICAAP covering risk quantification and capital planning. This tools are covering the following themes: 1) Risk identification; 2) IRRBB 3) Credit Concentration risk 4) Operational risk 5)Capital planning


Briefing Note

ICAAP & ILAAP Internal Self-Assessment

Leveraging on its experience and in line with market practices, Avantage Reply has developed ICAAP ILAAP self assessments tools. Interactive and easy to use, the self assessment tools cover the key building blocks of ICAAP and ILAAP frameworks and provide an overview that will help benchmarking frameworks in place against supervisory expectations and best practices. ICAAP and ILAAP integrated at the highest level of the organization is key for a proper use of both processes into the decision making process.