How to Structure a Credible RAF Public Disclosure to the Bank of England

The second round of RAF disclosures made one thing clear: the Bank of England reads these documents forensically, benchmarks them across firms, and treats vague assurance as a signal of weak underlying capability. A disclosure that lists policies and committees without showing what the firm can actually do in resolution will attract follow-up. One that walks the reader through tested capabilities, acknowledged gaps, and credible remediation reads as the output of a firm that takes resolvability seriously.

Start from the self-assessment, not a communications brief

The public disclosure is a derivative document. The primary artefact is the internal self-assessment submitted to the PRA, which runs to hundreds of pages and reflects the firm's honest view of its capabilities against the eight resolvability outcomes. If the disclosure team starts with a blank page and a stakeholder map, the document will drift from the self-assessment and the gap will be visible. Build the disclosure as a faithful public summary, with the self-assessment open on the desk.

Structure around the three resolvability outcomes, then the barriers

The Bank expects disclosures organised around the three outcomes: adequate financial resources, continuity through resolution, and coordinated communication and restructuring. Within each, address the relevant barriers directly: valuations, funding in resolution, operational continuity, restructuring planning, management information, and so on. Firms that invent their own structure, or bury the outcomes inside a corporate narrative, make the Bank's benchmarking harder and signal unfamiliarity with the framework's logic.

For each capability area, the disclosure should answer four questions in order: what the capability is required to do, how the firm has built it, how it has been tested, and what the test revealed. The fourth is where most disclosures fall short.

Treat testing evidence as the core of the document

The Bank has been explicit that assurance through testing distinguishes credible capability from paper capability. A disclosure that references a 2023 valuations dry run, names the scope, states what was exercised, and notes the lessons learned carries weight. A disclosure that says valuations capability has been "developed and embedded" carries none. Where testing has been limited, say so and explain the forward testing plan with dates.

Firms often hesitate to name specific exercises for fear of implying weakness. The opposite is true: specificity is read as confidence, generality as discomfort.

Handle shortcomings and thematic findings directly

The Bank's public thematic findings, whether on valuations, funding in resolution, or restructuring planning, sit in the supervisor's mind when they read your disclosure. If you were named or implicated, address it. If the thematic issue applies to your firm and you have not been publicly identified, address it anyway. Silence on a known industry issue reads as either poor self-awareness or deliberate omission.

For each acknowledged gap, include: the nature of the shortcoming, the root cause in plain terms, the remediation work underway, the owner at executive level, and the date by which the firm expects the capability to be fully in place. Vague commitments to "continue enhancing" are read as drift.

Align board attestation, executive ownership, and narrative tone

The board is attesting to the accuracy of the disclosure. If the narrative tone is more confident than the self-assessment supports, directors are exposed. The accountable executive for each capability should have reviewed the relevant section and be able to defend every claim in a supervisory meeting. A useful test: would the SMF holder for resolution be comfortable reading any paragraph aloud to the PRA? If not, redraft.

What good looks like

A strong disclosure is shorter than a weak one. It uses concrete numbers, named exercises, specific dates, and plain English. It reads as though written by people who have run the capabilities, not by people describing them from a distance. It leaves the reader, whether a supervisor, a counterparty, or a rating analyst, with a clear picture of what the firm would actually do on resolution weekend.

Next step

Before the next disclosure cycle, commission an honest internal review comparing the last published disclosure line by line against the current self-assessment and the Bank's most recent thematic findings. The divergences are your drafting agenda.

Frequently Asked Questions

How much detail on testing is too much?

There is a commercial and security line around naming counterparties, specific systems, or exploitable operational detail. Short of that, more specificity on scope, scenario, and findings is almost always better. If legal or security concerns block disclosure of a particular test, say a test occurred and summarise the lessons without the sensitive detail.

Should the disclosure match the self-assessment word for word?

No, but it must not contradict it. The self-assessment is longer, more technical, and covers matters the Bank does not expect to be public. The disclosure is a faithful summary. Any claim in the disclosure should be directly supported by material in the self-assessment.

How should we handle capabilities that are partially in place?

State the position clearly: what is operational, what is in build, what is planned, and the sequencing. Partial capability honestly described is credible. Partial capability described as complete is a supervisory problem waiting to happen.

Who should sign off the final draft?

The board, on the recommendation of the accountable SMF holder, with sign-off from the chairs of the risk and audit committees. The general counsel and head of regulatory affairs should confirm consistency with the self-assessment and with recent supervisory correspondence.