On July 31 ISDA, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) submitted to the Trading Book Group (TBG) of the Basel Committee on Banking Supervision (BCBS) a technical paper on the sensitivity based approach as a further response to the firm-wide quantitative impact study (QIS) instructions on the Fundamental Review of the Trading Book (FRTB). This letter followed a detailed industry response submitted on July 17.