The approach of the business to assessing the adequacy of its internal capital to support current and future activities is contained in RiverRock’s ICAAP document. This process includes an assessment of the specific operational, business, credit and market risks to RiverRock’s business and the internal controls in place to mitigate those risks. These are tested under different scenarios in order to provide a robust picture of exposures for the business. Finally, an assessment is made of the probability of occurrence and the potential impact, in order to arrive at a level of required capital.
As a result of this, the Firm has concluded that it does not need any further regulatory capital to meet its requirements under Pillar 2.
RiverRock has adopted a remuneration policy that complies with the requirements of chapter 19A of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”), as interpreted in accordance with the FCA’s guidance publication entitled “General Guidance on Proportionality: The Remuneration Code (SYSC 19A) & Pillar 3 Disclosures on Remuneration (BIPRU 11)” and subsequent items of guidance issued by the FCA, including its document entitled “Frequently Asked Questions on the Remuneration Code”.
As BIPRU limited licence firms, RiverRock falls within proportionality level 3. RiverRock has concluded, on the basis of its size and the nature scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the partners or directors (as applicable) set, and oversee compliance with, RiverRock’s remuneration policy including reviewing the terms of the policy at least annually.
As at the accounting reference date, RiverRock currently sets the variable remuneration of its partners or directors (as applicable in a manner which takes into account firm performance, by reference to individual performance and the overall results of RiverRock. As permitted for firms falling within proportionality level 3, RiverRock takes into account the specific nature of its own activities (including the fee based nature of its revenues) in conducting any risk adjustments to awards of variable remuneration and, given the nature of its business, has disapplied the requirement under the Remuneration Code to make post risk adjustments.