When to submit a PIN form
Firms must submit a PIN to the PRA if they plan to issue or amend, or have issued or amended, terms of a capital instrument either at solo, sub-consolidated or group level or any combination of these.
Before classifying an instrument as CET1 instrument, firms must apply for an Article 26(3) permission, which once granted, extends to all future CET1 issuances on identical and substantially the same terms. See the CRR permissions page for more details on CRR permission requirements.
Where a proposed CET1 instrument issuance is identical to an instrument by the firm for which the firm has received a CRR Article 26(3) permission, no notification is required.
Firms are generally required to notify the PRA at least one month before the intended date of issuance, amendment or variation to the terms of each CET1 or AT1 capital instrument, that will count towards regulatory capital resources or own funds, either at solo, sub-consolidated or group consolidated level or any combination of these. However, we may be prepared to accept less than one month’s notice in exceptional circumstances that make it impracticable to give one month’s notice. In such circumstances, a firm must submit an explanation on why it believes there are exceptional circumstances that mean we should accept a shorter notice period, along with the PIN form as far in advance of the issuance or amendments as practicable in those circumstances. Firms may also submit a PIN form when the associated capital instrument’s date of issue or amendment is uncertain.
Firms can notify us, as soon as is reasonably practicable, after issuing or amending the terms of a capital instrument if the conditions set out in the relevant PRA rules are met.
In case of Tier 2 instruments, we require notification of issuance or amendments on or after the issue date (post-issuance notification). We expect that, notwithstanding the post-issuance notification requirement for Tier 2 instruments, firms should discuss new issuances of Tier 2 instruments which include new or complex features that could affect their capital eligibility with the PRA prior to issuing such instruments.
In case of amendments to a capital instrument, firms should evaluate whether the proposed changes would affect the eligibility of the instrument and, in the case of a CET1 instrument, whether the CRR Art 26(3) permission granted would still be valid.
The PRA expects the relevant Senior Management Function (SMF) to take responsibility for ensuring the quality of the capital structure overall. This includes being accountable for the quality of notifications to the PRA under the PIN requirements.
See below a table and flow chart that illustrates the PIN requirements for CRR firms.
Table: Summary of PIN requirements
| Capital instruments |
Comparisons to terms previously reviewed by the PRA |
Notification requirements |
| CET1 |
Identical |
No notification requirement |
| Substantially the same |
As soon as reasonably practical after issuance/amendment |
| Not substantially the same |
At least one month in advance |
| AT1 |
Substantially the same |
As soon as reasonably practical after issuance/amendment |
| Not substantially the same |
At least one month in advance |
| Tier 2 |
Substantially the same |
As soon as reasonably practical after issuance/amendment |
| Not substantially the same |
