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

ISDA AGM Studio: Scott O'Malia and Chris Edmonds

Christopher Edmonds, president, fixed income & data services, at Intercontinental Exchange, speaks with Scott O’Malia, ISDA CEO, about how market volatility, regulatory change and technological transformation are reshaping global markets. The discussion explores what recent volatility has meant for participation,...

ISDA AGM Studio: Bill Borden, Microsoft

Bill Borden, corporate vice president, worldwide financial services, at Microsoft, speaks with Mark New, ISDA’s co-head of digital transformation and senior counsel, about how artificial intelligence (AI) is shaping the future of financial markets and the key factors firms should...

ISDA AGM Studio: Heath Tarbert

Heath Tarbert, president of Circle, speaks with ISDA CEO Scott O’Malia about the primary applications of stablecoins in derivatives markets and how key legal considerations – including bankruptcy treatment and settlement finality – are being addressed as digital assets become...

ISDA AGM Studio: Yuval Rooz

Yuval Rooz, co-founder and CEO of Digital Asset, speaks with ISDA CEO Scott O’Malia about the growing momentum behind tokenization, the most compelling use cases for derivatives markets and the remaining hurdles that need to be addressed to enable widespread...