Consultation Response on Internal Default Risk Model Requirements

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

Joint Letter on Simplification of EU Taxonomy

On October 6, ISDA, the Association for Financial Markets in Europe (AFME), the European Fund and Asset Management Association (EFAMA), the European Association of Co-operative Banks (EACB) and the European Banking Federation (EBF) published a policy statement in support of...

Paper on Removal of SI Regime

On October 10, ISDA, the Association for Financial Markets in Europe (AFME) and the International Capital Market Association (ICMA) published a paper on the practical implications of the recent discontinuation of the systematic internalizer (SI) regime for derivatives, bonds and...

Episode 52: Innovative Thinking

The pace of change in derivatives markets shows no sign of letting up, with rapid evolution across trading, regulation and technology. Industry veteran Don Wilson, founder of trading firm DRW, talks to The Swap about some of the biggest trends....