About · Partner profile
Mark Dougherty, CPA (CAN), is a co-founder and managing director of RiskTAE and the firm’s technical lead. A Canadian Chartered Professional Accountant and risk practitioner, he leads the advisory, consulting and training work and directs development of the RisKIT prudential models.
He has more than 30 years in financial services, over 20 of them in risk management, has served as an interim chief risk officer, and writes the firm’s articles on capital, the ICAAP and the Basel reforms.
Qualifications
Mark is a Chartered Professional Accountant, the professional accounting designation in Canada, represented nationally by CPA Canada. The CPA brought Canada’s three accounting designations (chartered accountant, certified management accountant and certified general accountant) together in 2014, and Mark also holds the Certified Management Accountant designation from before that merger. He is an international associate of the AICPA.
For a bank, building society or insurer, it means the numbers in an ICAAP, ILAAP or ORSA are built and challenged by a qualified accountant who reads them the way the finance director and the auditors will.
Experience
Mark has worked across fintech, capital markets, investment and retail banking, asset management, and general and life insurance. He has served as an interim chief risk officer and has worked in London, New York and Toronto, among other financial centres.
He contributes risk management lectures to the University of Cambridge’s Banking Executive Programme and presents risk seminars internationally. As a senior partner in Risks Explained Ltd he has written online courses on the Basel reforms to credit, market and operational risk, and he is the author of books and articles on risk management.
At RiskTAE
Mark leads Risk Advisory: ICAAPs and ILAAPs, Basel 3.1 implementation, recovery planning and independent reviews. He leads Risk Education, including board and in-house courses, and directs the design of the RisKIT models.
He writes about Basel 3.1, the ICAAP, the strong and simple regime for small banks and operational risk capital.
Writing
In February 2026 ACCA’s AB magazine published Don’t underestimate Basel reforms, written with Benn Pople. His articles for RiskTAE are listed below.
Insights
A solvent exit analysis is the PRA's requirement for a non-systemic UK bank or building society to show how it could stop its PRA-regulated activities in an orderly way while still solvent. Chapter 7 of the Recovery Plans Part has applied since 1 October 2025, with the PRA's expectations set out in SS2/24.
By Mark Dougherty, CPA (CAN) · 8 min read
SS4/25 is the PRA supervisory statement that sets its expectations of the ICAAP for small domestic deposit takers. It replaces SS31/15 for SDDTs from 1 January 2027, and its expectations on how often an SDDT updates its ICAAP have applied since 20 January 2026, when PS4/26 brought the two-yearly cycle into force.
By Mark Dougherty, CPA (CAN) · 8 min read
A wind-down plan sets out how an FCA-regulated firm would close its business in an orderly way, with enough money and people to return client assets and settle what it owes without harming customers or markets. This template follows the FCA's Wind-down Planning Guide section by section, with the MIFIDPRU and payments rules that sit alongside it.
By Mark Dougherty, CPA (CAN) · 8 min read
An ORSA, or Own Risk and Solvency Assessment, is an insurer's own assessment of the risks it faces and the capital it needs to stay solvent over its business plan, including under stress. Under Solvency UK the PRA expects the board to own it, use it in decisions and report the results to the PRA.
By Mark Dougherty, CPA (CAN) · 7 min read
Which prudential assessment a firm needs depends on its regulator and its business. UK banks and building societies write an ICAAP, an ILAAP and a recovery plan, plus a solvent exit analysis if non-systemic; FCA investment firms run an ICARA; Solvency UK insurers write an ORSA; and the FCA expects payment and e-money firms to keep a wind-down plan.
By Mark Dougherty, CPA (CAN) · 7 min read
Recovery indicators are the capital, liquidity, profitability and asset quality measures a bank sets in its recovery plan to warn that it is moving towards a stress in which recovery options may be needed. SS9/17, last updated in March 2026, expects them calibrated to the firm's own buffers and tested against severe scenarios.
By Mark Dougherty, CPA (CAN) · 8 min read
An ICARA, or Internal Capital Adequacy and Risk Assessment, is the process an FCA investment firm under MIFIDPRU uses to identify the harms its business could cause, decide the own funds and liquid assets it needs to cover them and to wind down in an orderly way, and record the result for its board and the FCA.
By Mark Dougherty, CPA (CAN) · 9 min read
An ILAAP, or Internal Liquidity Adequacy Assessment Process, is a bank's own assessment of whether its liquidity resources and funding are adequate in amount and quality, now and under stress. The PRA Rulebook requires one from every bank and building society, and the PRA reviews it in the liquidity SREP to set individual liquidity guidance.
By Mark Dougherty, CPA (CAN) · 9 min read
The PRA buffer, also called Pillar 2B, is capital a bank or building society should hold on top of its Total Capital Requirement (Pillar 1 plus Pillar 2A) and its combined buffer, to absorb losses in...
By Mark Dougherty, CPA (CAN) · 9 min read
A skilled person review is an independent report the PRA requires under section 166 of FSMA on a matter it wants analysed, monitored or put right, usually written by a professional services firm and paid for...
By Mark Dougherty, CPA (CAN) · 8 min read
The Business Indicator is the measure of size that sets a UK bank’s Pillar 1 operational risk capital from 1 January 2027. It is the sum of three components taken mainly from the income statement, each...
By Mark Dougherty, CPA (CAN) · 8 min read
Pillar 2A is the firm-specific capital the PRA requires a bank or building society to hold on top of its Pillar 1 minimum, for risks Pillar 1 does not capture or does not capture fully, such...
By Mark Dougherty, CPA (CAN) · 7 min readNext step
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