Peregrine & Black Investment Management Limited is authorised and regulated by the Financial Conduct Authority. FCA Firm Reference Number: 757727. The registered address is 3rd Floor Northside Argyle House, Joel Street, Northwood Hills, Middlesex, HA6 1NW and the Head Office is located at 65 Curzon Street, Mayfair, London W1J 8PE.

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Pillar 3 Disclosure


These disclosures are made in accordance with the rules of the Directive 2013/36/EU (Capital Requirements Directive (CRD IV)) and the Regulation No 575/2013 (Capital Requirements Regulation (CRR)) of the European Parliament and of the Council of 26 June 2013 relating to minimum capital requirements (known as “Pillar 3” requirements in the Basel II and the Basel III Accord and its European transposition by the CRR). It is this application of the CRD IV and CRR that requires Peregrine & Black Investment Management Limited (PBIM) to make these disclosures.

The CRR framework consists of three ‘Pillars’:

  • Pillar 1: Minimum capital requirements
  • Pillar 2: Supervisory review process: the need to assess whether the capital held under Pillar 1 is sufficient to meet the additional risks not covered by Pillar 1
  • Pillar 3: Disclosure requirements allowing market participants to assess information on a firms’ risks, capital and risk management procedures

The Financial Conduct Authority outlines the minimum disclosure requirements. The information below satisfies PBIM Pillar 3 requirement.

Frequency of Disclosure

PBIM will report its Pillar 3 disclosure annually or upon material change.

Location and Verification

These disclosures have been validated by the executive board. These disclosures are not subject to an audit except to the extent where they are equivalent to disclosures made under accounting requirements.

Scope of Application

This disclosure is made on an individual basis.

Risk Management

The firm undertakes its Individual Capital Adequacy Assessment Process (ICAAP) on an annual basis. The executive board is however mindful of the changing conditions. The firm’s ICAAP is completed by the organic compliance team and validated by the board. The Pillar 2 (ICAAP) capital requirements are excluded from this summary but are reviewed annually or upon material change.

The board of the firm, in addition to the risk mapping structure of the ICAAP, is very much involved with the day to day running of the company including the continual assessment of risk. The board manages the firm’s risks through a framework of policy and procedures having regard to relevant laws, standards, principles and rules (including FCA principles and rules) with the aim to operate a defined and transparent risk management framework.

Regulatory Risk

The firm’s main risk is changes in the legislative/political environment which could cause change in the regulations making the business less profitable or, potentially, removing the business altogether. To mitigate this risk, the firm monitors changes in legislation both domestically and, where possible, overseas and utilises external compliance assistance to ensure that it remains compliant. The firm has thus far continued to meet its obligations under MIFID II and Transaction reporting. PBIM’s robust compliance framework means that it is well positioned to tackle any future challenges and ensure that any inherent risk is mitigated.

Liquidity Risk

At the last balance sheet date, PBIM had cash balances and readily realisable investments amounting to £282,984, thus maintaining a surplus of £215,245 over the capital resource requirement.

Foreign Currency

The firm’s trades take place in traditionally stable foreign currency i.e. USD, EUR. Regardless, the firm employs a risk team to monitor exposure carefully at all times.

Trading/Position Risk

Any trading activity the firm conducts will be on a matched principal basis thus position risk is zero.

Credit Risk

This has been calculated using the standardised approach of credit risk. The requirement is calculated and the carrying value adjusted as required for appropriate risk.

Capital Resources Requirement September 2019

The Firm is BIPRU 50K firm and has a Pillar 1 minimum capital requirement which is the higher of its:

  • Base Capital Requirement (€50k) £44,240
  • Credit Risk + Market Risk Capital Requirements £35,437
  • Fixed Overhead Requirement £67,739

The Firm’s Pillar 1 Capital Requirement is therefore £67,739.

In accordance with its obligations under Pillar 2, the Firm has employed an analysis of the risks faced by it and allocated the following amounts of capital to the following risks:


Credit Risk                                                                                              £35,437

Legislative/Political Environment                                                      £20,000

Total Pillar 2 Requirement                                                                  £55,437

As this is below the Pillar 1 minimum capital requirement, PBIM’s capital requirement remains £67,739.

Capital Resources and Surplus over Capital Resources Requirement

PBIM calculates its capital resources by adding together its tier 1 capital after deductions, together with any tier 2 and tier 3 capital it holds. Tier 1 capital comprises of share capital, share premium and externally audited reserves, less intangible assets.  PBIM does not hold tier 2 or tier 3 capital.

Tier 1 capital after deductions 264,879
Less: Capital Resources Requirement (67,739)
Surplus 197,140


PBIM holds a surplus of £197,140 in resources above its capital requirement. Capital adequacy has been calculated in compliance with GENPRU 2


BIPRU 11.5.18R requires that a firm makes a disclosure of details regarding its remuneration policy.

PBIM has 4 employees and 3 contractors. The remuneration for the directors is outlined in the firm’s written remuneration policy. Executive directors receive base salaries proportionate with companies of their size, with the added opportunity to enhance their performance by receiving bonuses linked to the performance of the firm.

PBIM has two key business activities and under BIPRU 11.5.20R, the firm does not consider that it is ‘significant in terms of size, internal organisation and nature and scope of its activities’ so is not required to disclose the quantitative information referred to in BIPRU 11.5.18R at the level of senior personnel.

The firm falls within FCA proportionality Level 3 and as such this disclosure is made in line with the requirements for a Level 3 firm.

Further Enquiries

Should you have any queries please contact:

Patrick Bullman