Brewin Dolphin Holdings PLC Pillar 3 Disclosures 2020 TABLE of CONTENTS
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Brewin Dolphin Holdings PLC Pillar 3 Disclosures 2020 TABLE OF CONTENTS 1. Executive Summary ..................................................................................................... 2 2. Group Overview ........................................................................................................... 2 3. Regulatory Framework ................................................................................................. 4 4. Scope of Application .................................................................................................... 4 5. Frequency of Disclosure .............................................................................................. 4 6. Means of Disclosure .................................................................................................... 4 7. Risk Management Objectives and Policies................................................................... 5 8. Own Funds .................................................................................................................. 8 9. Regulatory Capital Requirements .............................................................................. 10 10. Credit Risk ................................................................................................................. 11 11. Market Risk ................................................................................................................ 13 12. Operational Risk ........................................................................................................ 15 13. Liquidity Risk .............................................................................................................. 15 14. Remuneration Policy .................................................................................................. 16 1. EXECUTIVE SUMMARY The purpose of Pillar 3 disclosures is to provide information on the risks, capital, and risk management arrangements of Brewin Dolphin (“the Group”). As at 30 September 2020, the Group’s: • Total capital resources (£161.1m) exceeded Pillar 1 capital requirements (£57.4m); and • Total capital ratio (22.5%) sufficiently exceeded the own funds requirement (8%). 2. GROUP OVERVIEW The Group is a leading independently-owned Wealth Manager, with a network of branches in the United Kingdom, Channel Islands and the Republic of Ireland. As at 30 September 2020, total funds amounted to £47.6 billion, of which £41.2 billion was managed on a discretionary basis. 2.1. GROUP STRUCTURE The Group is controlled by Brewin Dolphin Holdings PLC (“BDH”), a FTSE 250 listed company incorporated in the United Kingdom. BDH consists principally of two wholly owned regulated trading subsidiaries: • Brewin Dolphin Limited (“BDL”), regulated by the Financial Conduct Authority (“FCA”); and • Brewin Dolphin Wealth Management Limited (“BDWM”) (comprising of the entities formerly known as Tilman Brewin Dolphin Limited and Investec Capital & Investments (Ireland) Limited), regulated by the Central Bank of Ireland (CBI). The Group’s lead regulator is the FCA. The Group has the following unregulated subsidiaries: • Brewin Dolphin MP, which holds the Group’s seed capital investment in its model portfolios. • In addition, during 2020, the Group acquired Mathieson Consulting Limited, an expert witness report writing service. All other Group companies are either dormant or nominee companies. Refer to Figure 1 below for details of the Group’s legal structure. 2 Figure 1 - Group Legal Structure1 Brewin Dolphin Holdings PLC 100% owned subsidiary 100% owned subsidiary Brewin Dolphin Wealth Brewin Dolphin Limited (Authorised and Regulated by the Management Limited Financial Conduct Authority) (Authorised and Regulated by the Central Bank of Ireland) 100% owned subsidiary 100% owned subsidiary 100% owned subsidiary (as of 31st October 2019) Brewin Dolphin Mathieson Brewin Dolphin Capital & MP Consulting Limited Investments (Ireland) Limited (Authorised and Regulated by the Central Bank of Ireland) 2.2. NATURE OF BUSINESS The Group predominantly provides wealth management, financial planning and discretionary investment management to private clients in the UK and Ireland. The Group’s services are accessed either directly or indirectly, as follows: • Direct access: private individuals, charities and corporates; and • Indirect access: intermediaries where the Group provides investment management services for the intermediaries; the underlying clients are typically private individuals. 2.3. BUSINESS STRATEGY The Group’s vision is to become the leading provider of personalised wealth and investment management services in the UK and Ireland, delivering a compelling client proposition, rewarding careers and sustainable shareholder returns. It aims to achieve this vision by taking an integrated, advice-led approach to protecting and growing clients’ wealth, combining its experience and expertise in financial planning and investment management. Refer to the “Our Strategy” section of the Group’s Annual Report and Accounts 2020 for further details of the Group’s strategy. 1 Excluding dormant and nominee companies 3 3. REGULATORY FRAMEWORK The Capital Requirements Directive IV (“CRD IV”) of the European Union established a revised regulatory capital framework across Europe, which governs the amount and nature of capital that credit institutions and investment firms must maintain, and the manner in which capital resources and requirements are disclosed. This framework primarily consists of three pillars: • Pillar 1: outlines the minimum capital requirements firms are required to meet for credit and market risk, and the Fixed Overhead Requirement; • Pillar 2: requires firms to assess the amount of internal capital they consider adequate to cover all of the risks to which they are, or are likely to be, exposed. This is implemented through the Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by the Group; and • Pillar 3: requires firms to publicly disclose certain details of their risks, capital, and risk management arrangements. A detailed assessment of the requirements under Pillars 1 and 2 has been completed through the Group’s ICAAP, which is reviewed periodically by the FCA. The disclosures outlined in this document meet the obligation with respect to Pillar 3 and the requirements outlined in Articles 431- 455 of the Capital Requirements Regulation (“CRR”). 4. SCOPE OF APPLICATION The capital reporting requirements outlined in section 3 apply to the Group. The Group has two regulated entities, BDL and BDWM, which are IFPRU €125k Limited Licence Firms. For accounting and prudential purposes, BDL and BDWM are fully consolidated into the Group. All disclosures in this document are for the year ended 30 September 2020. 5. FREQUENCY OF DISCLOSURE The Group publishes Pillar 3 disclosures on at a least an annual basis following the publication of its financial statements. Given the scale and range of its operations and complexity, the Group currently assesses that there is no need to publish some or all of the Pillar 3 disclosures more frequently than annually. 6. MEANS OF DISCLOSURE These disclosures have been compiled to satisfy those required under Pillar 3 and have not been audited. Where the equivalent disclosures have been made in the Group’s Annual Report and Accounts 2020, this document indicates where they can be found. The Group publishes its Pillar 3 disclosures on its website. BDWM Pillar 3 disclosures are published separately on its own website. 4 7. RISK MANAGEMENT OBJECTIVES AND POLICIES Effective risk management is key to the success of delivering our strategic objectives. Our approach to risk management continues to evolve as the risk landscape changes; it ensures timely identification, assessment, and management of the principal risks to our business. The primary objectives of risk management at Brewin Dolphin are to ensure that there is: • A strong risk culture so that employees are able to identify, assess, manage and report against the risks the business is faced with; • A swift and effective response to risk events and potential issues in order to minimise impact; • A defined risk appetite within which risks are managed: and • An appropriate balance between risk and the cost of control. Our approach is to maintain a strong control framework to identify, monitor and manage the principal risks we face, adequately quantify them and ensure we retain sufficient capital in the business to support our strategy. The key parties involved in the risk management process within the Group and their respective responsibilities and an explanation of the how risk management is structured within the Group, is set out in Figure 2 below. 5 Figure 2 – Overall Risk Management Framework We follow industry practice for risk management through the three lines of defence model. The first line is the business that owns and manages the risk, the second line are the functions that monitor and facilitate the implementation of effective risk management practices, and the third line is independent assurance provided by audit. The Board reviews the effectiveness of this Risk Management Framework and undertakes an assessment of the principal and emerging 6 risks, receiving reports on internal control from the Audit and Risk Committees and debating key risks for the Group following more detailed work by the Risk Committee. 7.1 RISK APPETITE Risk appetite is an assessment of a firm’s willingness to take risk to achieve its strategic objectives. The Group