On September 11, ISDA responded jointly with the other associations (IIF/IBFed/GFMA) to the BCBS consultation on interest rate risk in the banking book (IRRBB). The response supports the goal of ensuring that banks continue to manage IRRBB effectively, and that appropriate transparency is achieved to properly gauge banks’ IRRBB exposure. However, it reiterates these goals can be pursued within a Pillar 2 and Pillar 3 frameworks. Given the nature of IRRBB, the industry does not believe that a Pillar 1 approach is appropriate.