On October 22, 2020, ISDA submitted a response to a consultation by the European Banking Authority (EBA) on the requirements of the internal default risk model to estimate default probabilities and losses given default.
Institutions using an alternative internal model to compute own funds requirements for market risk and holding positions in traded debt and equity instruments through trading desks covered by internal models approach permission are required to additionally compute an own funds requirement using an internal default risk model.
One of the requirements under the internal default risk model is for institutions to be capable of modelling the default of individual issuers, as well as the simultaneous default of multiple issuers, and computing the impact of those defaults on the market values of the positions that are included in the scope of that model. This consultation specifies the requirements that an institution’s internal methodology or external sources are to fulfil for estimating default probabilities and losses given default.
The industry appreciates the EBA’s efforts in developing regulatory standards for the sources used to develop default probabilities and losses given default. However, there are concerns about using the internal rating-based approach, which was built and designed for banking book activities. Utilizing this approach for market risk could lead to model design inconsistencies.
Documents (1) for Consultation Response on Internal Default Risk Model Requirements
Latest
CDM: User Journey from Concept to Production
The Common Domain Model (CDM) is a standardized, machine-readable and executable model for representing financial products, lifecycle events and contractual information. By providing an open source shared language across firms and platforms, it supports interoperability, automation, resource optimization and reduced...
ISDA DTF Tokyo SOM Opening Remarks
ISDA Derivatives Trading Forum Tokyo, October 23, 2026 Opening Remarks Scott O’Malia ISDA Chief Executive Good afternoon, and welcome to the ISDA Tokyo Derivatives Trading Forum. Thanks for joining us today, and a big thank you to our sponsors,...
Transforming Asset Management: SOM Remarks
Transforming Asset Management October 23, 2026 Welcoming Remarks Scott O’Malia, ISDA CEO Good morning, and welcome to ISDA’s Transforming Asset Management event. It’s great to be back in Tokyo for Japan Weeks. Now in its fourth year, Japan Weeks...
Response on Dividend Stripping
On October 14, ISDA, the Association for Financial Markets in Europe (AFME) and the International Securities Lending Association (ISLA) submitted a joint response to the Dutch Ministry of Finance on its proposed measures on dividend stripping. While supporting the policy...
