
ICARA and Prudential Risk Support
Thistle Initiatives supports regulated firms with ICARA, capital adequacy and prudential reporting requirements
We work with:
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SNI and non-SNI MIFIDPRU investment firms
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Consolidated investment firm groups
- Select banks and PRA-regulated firms
Our focus is on delivering proportionate, well-evidenced frameworks that stand up to regulatory scrutiny and work in practice.
1000+
Successful FCA applications
Winner of Best Financial Services Compliance Consultancy 2020 - 2024
2000+
Happy customers served
Our Prudential Services
Internal Capital Adequacy and Risk Assessment (ICARA)
We support investment firms with the preparation, review, and ongoing maintenance of their ICARA, including:
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Capital and liquidity planning
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Stress testing and scenario analysis
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Recovery and wind-down planning
We also assess whether ICARA frameworks are aligned with FCA expectations, including the Overall Financial Adequacy Rule.
Internal Capital Adequacy Assessment Process (ICAAP)
For banks and PRA regulated firms, we provide targeted support on ICAAP, including:
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Capital adequacy assessments and documentation
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Risk identification and stress testing
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Preparation for supervisory review
We take a proportionate, pragmatic approach aligned to PRA expectations.
Consolidated Investment Firm Groups (IFG)
Support with group level capital and liquidity under MIFIDPRU and the CRD, including consolidated assessments and governance.
This includes helping groups understand how risks, capital and resources should be assessed across entities and on a consolidated basis.
Wind-Down and Recovery Planning
We develop credible wind down and recovery plans tailored to a firm’s business model and regulatory permissions.
Our team has extensive experience supporting both investment firms and banks, with a strong understanding of regulatory expectations and supervisory focus in this area.
Prudential Regimes in Practice:
Investment Firms Prudential Regime
The IFPR introduced a requirement for all firms in scope of the regime to complete an internal capital adequacy and risk assessment (ICARA) process. Through the ICARA process, firms identify the risk of harm in their operations and provide appropriate resources to mitigate harm, whether as a going concern or when winding down.
How Thistle Initiatives works
Step 1: Applying MIFIDPRU or CRD to your business model
Capital and liquidity requirements are more than just numbers and calculations. Our prudential services help you interpret the requirements based on your firm’s permissions and activities, whether under the Investment Firms Prudential Regime (IFPR) or the Capital Requirements Directive (CRD), and deliver against regulatory expectations in practice.
Step 2: Supporting ICARA (and ICAAP where relevant)
Preparing your ICARA, ICAAP and prudential regulatory reporting. Our ICARA and ICAAP templates are available as standalone offerings or alongside consulting support, depending on the level of input you need.
Step 3: Independent challenge and regulatory readiness
Reviewing the effectiveness of your ICARA or ICAAP documentation to ensure you have met the overall financial adequacy requirements and are well prepared for regulatory review and challenge.
FCA and PRA Regulatory Reporting
Where firms need ongoing support with FCA regulatory reporting, data quality or RegData processes, this is covered through our dedicated FCA Regulatory Reporting and RegData Support service.
What Our Investments Clients Say
“Our experience of working with Thistle Initiatives to add our CASS permissions has been great. Thistle helped to create the application to vary our FCA permissions and helped to respond to the FCA’s detailed questions following submission. Thistle assisted quickly and clearly at all times, including during the more complex aspects of the process.”
“Our experience of working with Thistle Initiatives has been exceptionally good. After due consideration and comparison of various service providers, WMG Advisors engaged Thistle to perform an external review of our systems and controls, our policies and procedures and to provide ongoing training to meet our compliance needs. Thistle deployed serious resources to the project, and provided comprehensive analysis and recommendations. Thistle has responded quickly and clearly to all of our requests to date. We continue to be impressed with both the methodology and the people that we deal with throughout their organisation.”
“Thistle Initiatives provide us with invaluable expertise with their ongoing compliance support and delivered end-to-end assistance with our FCA application to add Alternative Investment Fund Management to our permissions. The service from the team is always on-point and efficient; we highly recommend them.”