ICAAP / ILAAP hiring: what to look for in a senior risk officer

# ICAAP / ILAAP hiring: what to look for in a senior risk officer

A senior risk officer in a regulated EU bank, investment firm or significant payment institution lives or dies on the quality of the ICAAP and ILAAP. The Pillar 2 documents are the centrepiece of the SREP exercise, and they are the documents the home-state supervisor will most aggressively challenge.

This is a hire where the CV-to-reality gap is enormous. Plenty of candidates have "led the ICAAP" - very few have personally argued the model, the scenarios, the buffer calibration in front of a supervisor.

What separates the talker from the doer

• The doer can describe the **exact stress scenario** they ran, with the numbers.
• The doer has had a **finding** on the ICAAP and can describe how it closed.
• The doer can name the **supervisory dialogue** points - not just the documents.
• The doer has **opinions** on credit and operational risk weight calibration that survive scrutiny.

Screening questions

• *"Walk me through the last ICAAP cycle you authored or owned. Pick the most contentious assumption you made and tell me how you defended it."*
• *"What was your supervisor's biggest pushback at the last SREP, and what changed in the next cycle?"*
• *"Describe an operational-risk scenario you added that the business did not want to add. How did you get it in?"*

Frameworks you need them to have actually used

• **CRR / CRD V/VI** for credit institutions.
• **IFR / IFD** for MiFID investment firms.
• **PSD2 own funds / capital requirements** for PIs and EMIs.
• **EBA / EIOPA guidelines** on stress testing, scenario design, recovery plans.
• **BCBS 239** if data lineage matters at scale.

Red flags

• Theoretical capital ratios but no actual stress-test cycle owned.
• Cannot name a single SREP finding.
• Defers every methodology question to "the consultants".

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