On January 16, ISDA and the Securities Industry and Financial Markets Association (SIFMA) submitted a joint response on the US Basel III ‘endgame’ notice of proposed rulemaking (NPR). The response focuses on the Fundamental Review of the Trading Book (FRTB), the revised credit valuation adjustment (CVA) framework, the securities financing transactions requirements and elements of the standardized approach to counterparty credit risk rules.

Based on an industry quantitative impact study with input from eight US global systemically important banks, the proposed FRTB and CVA framework would result in a 129% increase in market risk and CVA risk-weighted assets under the new expanded risk-based approach versus the current US standardized approach.

In the response, the associations propose a number of calibration changes to ensure the rules are appropriate and risk sensitive and avoid adverse consequences to US capital markets.