Pillar 3 Disclosures


The European Union (“EU”) Capital Requirements Directive (“CRD”) was adopted by the EU in 2006 and came into effect in Ireland on 1 January 2007. The CRD applies to all investment firms authorised under the Markets in Financial Instruments Regulations 2007 (“MiFID”).

The affect of implementing this directive required regulated firms to amend the process in which they calculate their capital requirements.

The revised framework consists of 3 “Pillars” or components:

Pillar 1 – sets out the minimum capital requirements of regulated firms;

Pillar 2 – requires firms to assess capital adequacy requirements taking into consideration all risks in the business;

Pillar 3 – requires firms to disclose risk exposures, processes and capital information to promote greater market discipline and transparency.

Therefore, the disclosures made in this document refer to Pilot View Capital Limited (“the Firm” or “PVC”), and represent disclosures as at 31st March 2013.

Risk Management

The Firm is governed by a Board of Directors (the “Board”) and Senior Management who determine the business strategy and risk appetite. They are responsible for establishing and maintaining the corporate governance and risk management frameworks to identify risks facing the business. The Firm’s risk management process is continually evolving and is appropriate given its nature, scale and complexity.

As a result of the Firm’s risk assessment process, the Board of Directors and Senior Management have determined that Reputational, Business and Operational risks are the key material risks facing the business. The risks facing the business are continually evaluated to determine adequate capital requirements.

Capital Adequacy

The Firm’s capital management objectives are as follows:

To maintain a strong capital base to support the strategic development of the business.
To comply with the capital requirements of the Central Bank of Ireland.

As mentioned above, the Firm considers Reputational, Operational and Business Risks to represent the key material risks to the business.

Reputational Risk

Reputational risk covers the impact of poor performance on the firms ability to generate profits, the impact of the loss of a fund manager and the impact of the loss of key customers. This risk is managed primarily by having processes for quality customer care and by the fund manager being a substantial shareholder in the firm and an investor in the funds.

Operational Risk

The risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. This risk includes IT, legal and compliance risk. The key components of operational risk management are identification, measurement , mitigation, monitoring and reporting. Operational risks are identified, measured and mitigated primarily through the operation of internal controls and procedures.

Business Risk

Business risk is the risk that the firms position, performance or prospects are negatively impacted by charges in the macroeconomic environment and/or changes in the competitive environment.

Business risk is managed through the development of business plans, corporate strategy and management oversight. Business plans and strategy generally evolve over time though where necessary may be subject to change as economic circumstances dictate.

Capital Resource

As at 31-3-2013 Pilot View Capital complied with the capital requirements of the Central Bank of Ireland.

Disclosure Location

The Board of Pilot View Capital has approved this disclosure statement and will continue to review its Pillar 3 Disclosures on an annual basis unless circumstances dictate the need for additional disclosure.

Pilot View Capital believes that the most appropriate location for this disclosure statement is the Pilot View Capital website



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