Pillar 3 Disclosure Document for the Year Ended 31 March 2020
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Pillar 3 Disclosure Document for the year ended 31 March 2020 Board – June 2020 Contents Page Executive Summary 2 1. Introduction 3 2. Risk Management Policies and Objectives 5 3. Capital Resources 11 4. Capital Adequacy 13 5. Credit risk 18 6. Operational Risk 26 7. Liquidity and Funding Risk 27 8. Other Risks 29 9. Remuneration paid to Code Staff 31 Appendix EBA own funds disclosure template 33 ______________________________________________________________________________________ Dudley Building Society Pillar 3 Disclosures 2020 1 EXECUTIVE SUMMARY This document presents the Pillar 3 disclosures of Dudley Building Society as at 31 March 2020. The table below provides an overview of the key metrics on capital adequacy. Key metrics 31 March 2020 31 March 2019 Available capital £m £m Total Common Equity Tier 1 23.6 22.9 Total Tier 2 capital 1.0 0.8 Total capital 24.6 23.7 Total risk weighted assets (RWAs) 179.3 150.9 Capital ratios % % Common Equity Tier 1 ratio 13.1 15.2 Total capital ratio 13.7 15.7 Total capital and buffer requirement 11.3 12.7 Leverage ratio Leverage ratio exposure measure £545.2M £445.2m Leverage ratio 4.3% 4.9% Liquidity ratios Liquidity coverage ratio 297% 197% Net Stable Funding Ratio 170% 168% ______________________________________________________________________________________ Dudley Building Society Pillar 3 Disclosures 2020 2 1. Introduction On 1 January 2014, the Capital Requirements Regulation (CRR) and the Capital Requirements Directive came into force and are together referred to as CRDIV or Basel 3. The Capital Requirements Directive governs how much capital all banks and building societies must hold to protect their Members, depositors and shareholders. The revisions introduced by CRD IV seek to strengthen the capital position of the sector and make it more resilient to financial and economic shocks. In the UK this is implemented by the Prudential Regulation Authority (PRA). Dudley Building Society’s primary aim is to ensure the protection of Members’ savings by having sufficient capital even during a significant economic downturn. 1.1. Framework The CRD determines a framework which in addition to capital requirements also requires disclosure of key pieces of information, such as risk exposures and risk assessment processes. Below are the three main “Pillars” which make up the CRD. Pillar 1: Minimum regulatory capital requirements relating to credit, market and operational risks. The Society meets the minimum capital requirements by applying the standardised approach to credit risk and the Basic Indicator Approach to operational risk. Pillar 2: Assessment of capital requirements by the Society through the Internal Capital Adequacy Assessment Process (ICAAP) and the PRA through the Supervisory Review and Evaluation Process (SREP) to determine whether additional capital should be held for specific risks not covered under Pillar 1; Pillar 3: Disclosure of key information about risk exposures, the management of those risks and capital adequacy. The Pillar 3 Disclosures are designed to promote market discipline through external disclosure of a firm’s risk management framework and risk exposures. For small societies such as the Dudley, the Pillar 1 assessment is based on a formulaic risk-based capital calculation focusing particularly on credit and operational risks to determine the Capital Resources Requirement. 1.2. Scope of application This document contains the Pillar 3 disclosures for the Dudley Building Society (PRA Number 161294). The principal office of the Society is 7 Harbour Buildings, The Waterfront, Brierley Hill, West Midlands, DY5 1LN. ______________________________________________________________________________________ Dudley Building Society Pillar 3 Disclosures 2020 3 1.3. Basis and frequency of disclosures This document sets out the Pillar 3 disclosure requirements of the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR) Pillar 3, as relevant to the size and complexity of the Society. The Pillar 3 disclosures have been prepared purely to comply with the Capital Requirements Directive, in seeking to explain the basis on which the Society has prepared and disclosed certain capital requirements and information about the management of certain risks. It also provides asset information and capital calculations under Pillar 1. Unless otherwise stated all information relates to the Society’s assets as at 31 March 2020. This document is updated at least annually to ensure that the disclosures, verification and frequency remain appropriate and will be based on the Society’s most recent audited financial statements. Confidential information and materiality Information is considered material if its omission or misstatement could change or influence the assessment of decision of a user relying on that information for the purpose of making economic decisions. No disclosures have been omitted on the basis of materiality or confidentiality. 1.4. External audit and verification Verification This document has been reviewed by the Society’s Assets & Liability Committee and approved by its Board in June 2020. External audit The disclosures provided in this document have not been subject to external audit except where they are equivalent to those prepared under accounting standards for inclusion in the Society’s audited financial statements for the year ended 31 March 2020. The disclosures do not constitute any form of Financial Statement and must not be relied upon in making any judgement on the Society. All figures within this document are correct as of 31 March 2020 unless stated otherwise. 1.5. Publication media and location The Pillar 3 disclosure document will be prepared and published on an annual basis and is available on the Society’s website (www.dudleybuildingsociety.co.uk). Should you require further information on this document please contact the Society Secretary at the principle office address. ______________________________________________________________________________________ Dudley Building Society Pillar 3 Disclosures 2020 4 2. Risk Management Policies and Objectives This section sets out the Society’s approach to managing risk. 2.1. Introduction Dudley Building Society is a traditional Building Society, developing and retailing financial products, principally in the form of mortgages and savings. In executing the Society’s strategy and in carrying out its routine business and activities, the Society is exposed to a number of risks. The primary goal of risk management is to ensure that the outcome of risk-taking activity is consistent with the Society’s strategy and risk appetite and appropriate for the level and types of risks it takes paying regard to regulatory guidance. Good risk management ensures there is an appropriate balance between risk and regard in order to optimise Member returns and, when issues arise they are managed for the best outcome for Members and the Society. The Society has a Risk Management Framework that documents the Society’s formal structure for managing risks and Board risk appetite. The Board delegates oversight of this area to a Risk Committee, which reviews risk limits, reporting lines, mandates and other control procedures. In addition, the Society’s Assets & Liabilities Committee (ALCO) is charged with the responsibility for managing and controlling the balance sheet exposures and the use of financial instruments for risk management purposes. 2.2. Society’s Risk Management framework The Society’s Risk management framework (“RMF”) provides the foundation for achieving risk management objectives through: - Articulating the Society’s risk management strategy, risk appetite, practices and procedures - Documenting a consistent framework - Establishing minimum standards around key risk management issues - Directing the approach to risk governance throughout the Society The RMF documents the Society’s approach to managing risk through: - Defining risk appetite - Detailing the three lines of defence model - Determining committee roles and responsibilities - Identifying roles responsible for key risks and oversight of risk decisions - Documenting the main risk management processes - Describing the key risks faced by the Society and how they are managed and mitigated - Listing out the key risk policies in use by the Society The three lines of defence model The Society adopts a three lines of defence model to separate risk management activities between: 1st line Those that own and take risks and implement controls; 2nd line Those that oversee, monitor and challenge the first line; and 3rd line Audit functions which provide fully independent assurance In addition, the risk management framework incorporates the requirements of the PRA’s Supervisory Statement SS20/15 “Supervising building societies’ treasury and lending activities”. Specifically, the Society has adopted the Limited Lending Approach and the Matched Treasury Approach to risk management from SS20/15. ______________________________________________________________________________________ Dudley Building Society Pillar 3 Disclosures 2020 5 2.3. Risk Governance: Board and Committee structure The Society’s Management structure is set by the Society’s Board of Directors, including via the establishment of a number of Committees which may include both Executive and Non‐Executive Directors to oversee the various sections of the Society’s business. The principal Committees from a Risk Management viewpoint are set out below. * Paul Doona is interim Chair of the Audit