On February 18, 2022, ISDA submitted a response to the European Banking Authority (EBA) consultation on implementing technical standards for the 2023 internal models benchmarking exercise. ISDA’s members welcome the EBA’s efforts to improve the effectiveness of the exercise, including through the renumbering of instruments, portfolios and notes that the EBA has incorporated into some of the instruments/portfolios. The growth of the hypothetical portfolios year on year requires considerably more maintenance and computation capacities for the internal models approach exercise. ISDA therefore requests that the number of instruments are kept stable moving forward.