On February 15, 2021, ISDA submitted a response to the European Banking Authority (EBA) on its consultation on the implementing technical standards for the 2022 internal models benchmarking exercise.
Article 78 of Directive 2013/36/EU (CRD IV) requires competent authorities to conduct an annual assessment of the quality of internal approaches used for the calculation of own funds requirements. To assist competent authorities in this assessment, the EBA calculates and distributes benchmark values against which individual institutions’ risk parameters can be compared. These benchmark values are based on data submitted by institutions as laid out in Commission Implementing Regulation (EU) 2016/2070, which specifies the benchmarking portfolios, templates and definitions to be used as part of the annual benchmarking exercises.
The industry appreciates the EBA’s efforts to harmonize the output of firms’ internal models. However, there is concern that the benchmarking exercise for market risk for IMA (internal model approach) banks is proposed to extend and also cover the Fundamental Review of the Trading Book alternative standardized approach (ASA). The industry appreciates that the EBA only aims to include information that is already part of the ASA calculation, but it will nevertheless be an additional burden to IMA banks.
The industry furthermore proposes that any ASA sensitivities that are reported use the industry standard common risk interchange format (SA-CRIF), as this has been widely tested and used by industry participants.
Documents (1) for ISDA Responds to EBA Consultation on Internal Models Benchmarking
Latest
Refreshing the FX Definitions
A lot has changed in the FX derivatives market since 1998, when the last set of standard definitions for FX transactions were published. Trading volumes have grown substantially, and average daily turnover has risen by six times. Market practices have...
ISDA & EMTA Publish New FX Definitions
ISDA and EMTA, Inc., the trade association for emerging markets, have jointly published a revised set of standard definitions for foreign exchange (FX) derivatives transactions, which update key market practices and consolidate various FX and FX-related product templates and provisions...
ISDA Position Paper on SFDR Review
On February 27, ISDA and the Association for Financial Markets in Europe (AFME) published a position paper on the European Commission’s (EC) proposed revisions to the Sustainable Finance Disclosure Regulation (SFDR 2.0). The paper welcomes the EC’s proposal as a...
ISDA Response to HKMA SFC Consultation on Clearing Rules
On February 27, ISDA responded to a joint consultation by the Hong Kong Monetary Authority (HKMA) and the Securities Futures Commission (SFC) on proposed amendments to schedule 2 of the clearing rules for over-the-counter (OTC) derivatives. The proposed amendments introduce...
