This example illustrates a situation of an undercapitalised group resulting from an undercapitalised unregulated parent holding company as described in paragraphs 23 and 25 of the Capital Adequacy Principles paper.
An unregulated holding company with two regulated 100% subsidiaries and one unregulated 100% subsidiary. Both regulated entities meet their solo requirements.
Unregulated Holding Company A1
| Assets | Liabilities |
Book-value participations in: Bank B1 | | Capital | 300 |
| 800 | Other liabilities (long term loan) | 800 |
| Insurance company B2 | 200 | | |
| Leasing company B3 | 100 | | |
| Total | 1,100 | Total | 1,100 |
Bank B1 (Subsidiary)
| Assets | Liabilities |
| Loans | 900 | Capital | 800 |
| Other assets | 400 | Other liabilities | 500 |
| Total | 1,300 | Total | 1,300 |
Insurance Company B2 (Subsidiary)
| Assets | Liabilities |
| Investments | 7,000 | Capital | 200 |
| | | General reserves | 100 |
| | | Technical provisions | 6,700 |
| Total | 7,000 | Total | 7,000 |
Unregulated Leasing Company B3 (Subsidiary)
| Assets | Liabilities |
| Leases | 2,000 | Capital | 100 |
| | | Other liabilities | 1,900 |
| Total | 2,000 | Total | 2,000 |
Group (consolidated)
| Assets | Liabilities |
| Bank loans | 900 | Capital | 300 |
| Other bank assets | 400 | General reserves | 100 |
| Insurance investments | 7,000 | Other bank liabilities | 3,200 |
| Leases | 2,000 | Technical provisions | 6,700 |
| Total | 10,300 | Total | 10,300 |
(i) Assume the solo capital requirements/solvency margins of the regulated companies are as follows:
| Requirement | Actual Capital | Surplus/(Deficit) |
| Bank B1 | 100 | 800 | 700 |
| Insurance Company B2 | 300 | 300 | 0 |
| "notional" capital proxy for the Leasing Company B3 | 150 | 100 | (50) |
(ii) Under the building-block prudential approach, the aggregated solo capital requirements and proxies (B1 : 100; B2 : 300; B3 : proxy of 150: Total : 550) are to be compared with the consolidated capital (300 +100 = 400). The group has a solvency deficit of 550 - 400 = 150.
(iii) Under the risk-based aggregation method, the solo capital requirements and proxies are again aggregated (550); the total requirements are compared to the sum of the capital held by the parent and its subsidiaries, deducted from the amount of the intra-group holding of capital [300 (parent) + 800 (B1) + 300 (B2) + 100 (B3) - 1,100 (participations) = 400]. Again, the group has a solvency deficit of 150.
(iv) Under the risk-based deduction method, in the balance sheet of the parent the book value of each participation is replaced by its surplus or deficit value, i.e. total assets minus liabilities and minus capital requirement/proxy of the subsidiary. The book-values of B1 (800), B2 (200) and B3 (100) are replaced by the solo surplus/deficit identified under (i): B1 (700), B2 (0), B3 (-50).
The revised balance sheet of the parent holding company is then as follows:
| Assets | Liabilities |
| Participations in: | | | |
| B1 | 700 | Capital | -150 |
| B2 | 0 | Other liabilities | 800 |
| B3 | -50 | | |
| Total | 650 | Total | 650 |
Again, the result of the calculation shows a group solvency deficit of 150.
(v) When there is an unregulated holding company, the total deduction method is not applicable.
(vi) Conclusions Although both regulated entities meet their own solo or sector solvency requirements, the financial conglomerate on a group-wide basis is undercapitalised. The explanation is twofold: first, there is excessive leverage in the group, as the parent has downstreamed debt to its subsidiaries in the form of equity capital, and secondly there is an undercapitalised unregulated entity in the group. As explained in the main text, the undercapitalisation of the group is a potential risk for both regulated entities. As shown in the example, the undercapitalisation can be revealed by applying appropriate measurement techniques for the assessment of capital adequacy at group level.