6.16 This section provides further details of the PRA's intention to conduct an off-cycle review of firm-specific Pillar 2 requirements within the PRA's existing Pillar 2 methodologies. In view of the timeline for implementation of the Basel 3.1 standards, the PRA would not expect firms to conduct a full Internal Capital Adequacy Assessment Process (ICAAP) for the purposes of this review. Therefore, the PRA does not plan to reset firms' Pillar 2 capital requirements fully through a full C-SREP process before day 1. Instead, the PRA intends to:

• adjust firms' Pillar 2 capital requirements to address double counts identified; and/or

• rebase [Rebasing means taking firms' existing nominal Pillar 2 requirement and rescaling it as a fixed percentage of projected RWAs under the Basel 3.1 standards. Given these Pillar 2 requirements are set as a percentage of total RWAs, they will continue to scale with changes in firms' RWAs arising from the implementation of the Basel 3.1 standards.] firms' variable Pillar 2A requirements and PRA buffer so that the changes to Pillar 1 RWAs do not result in unwarranted higher (or lower) Pillar 2 capital requirements where the relevant risk level has not changed.

6.17 The PRA will conduct a firm data collection exercise to inform the above adjustments, and further details will be announced in due course.