On February 29, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint response to the European Banking Authority’s (EBA) consultation on draft regulatory technical standards on the conditions for assessing the materiality of extensions and changes to the use of internal models under the Fundamental Review of the Trading Book (FRTB).
The associations highlight the importance of having qualitative and quantitative criteria in the rules that are proportionate and do not lead to unnecessary operational burdens that reduce the adoption of the internal models approach (IMA). The qualitative and quantitative criteria aim to determine whether model changes or extensions are material and require further review from the competent authorities.
The associations believe the suggested thresholds for both material model changes and extensions for changes in the subset of modellable risk factors require further review and provide recommendations for the thresholds. In addition, the suggested qualitative criteria for material model changes, particularly those related to a change to the structure of a desk or a change in the business strategy of a desk, should be placed under the additional information category. The associations also suggest the assessment and ex-ante notification period should be shortened.
Documents (1) for ISDA Responds to EBA on Changes to IMA under FRTB
Latest
Trading Book Capital: Scott O'Malia Remarks
Trading Book Capital: Capital Conundrum, Navigating Basel III Endgame February 5, 2026 Welcoming Remarks Scott O’Malia, ISDA Chief Executive Good afternoon, and welcome to ISDA’s Trading Book Capital event – it’s great to be here in New York. We...
ISDA In Review – January 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in January 2026.
ISDA Responds to RBI Unique Transaction Identifier (UTI) Proposals
On November 14, 2025, ISDA submitted comments to a Draft Circular from the Reserve Bank of India (RBI) proposing to mandate the global Unique Transaction Identifier (UTI) for all transactions in OTC markets for Rupee interest rate derivatives, forward contracts in Government...
How and Why Pension Funds Use Derivatives
With over $58 trillion in assets globally, pension fund managers are major participants in financial markets and play a vital role in helping to provide post-retirement incomes for plan employees. Meeting such an important goal requires careful consideration of investment...
