This response consolidates prior industry responses (issued successively on Jan 3rd, 6th and 19th, 2014, and listed separately at the ISDA website), by summarizing the main points from previous submissions and interactions, clarifying some of the industry’s positions, and by including a list of questions regarding securitization for further discussion. The major concerns of the industry are with the feasibility of the QIS timetable as currently envisioned, the proposed Standardized Approach and the liquidity horizon component of the Internal Model Approach (which pose significant implementation challenges), and the proposed treatment of credit and model-independent approval process. As such, the letter asks that BCBS consider the industry’s proposals and, if significant revisions in the proposed methodologies were to be undertaken, the industry would greatly appreciate, i) to be informed as soon as possible since significant changes may affect the banks’ ability to participate in the QIS, and ii) the opportunity to comment on such revised proposals.
Documents (2) for ISDA, GFMA & IIF Letter to the Trading Book Group of the Basel Committee on Banking Supervision, providing consolidated industry response to the Second Consultative Document on the Fundamental Review of the Trading Book (FRTB).
Latest
Response to BoE on Systemic Stablecoins
On February 10, ISDA responded to the Bank of England’s (BoE) consultation on a proposed regulatory regime for sterling-denominated systemic stablecoins. In the response, ISDA highlights that any regulatory framework should be assessed through the lens of prudent risk management...
SwapsInfo Full Year 2025 and Q4 2025
Trading activity in interest rate derivatives (IRD) and credit derivatives increased in 2025, reflecting shifting monetary policy expectations and broader market conditions. IRD traded notional rose by about 46% year-on-year, led by an increase in overnight index swaps (OIS). Index...
ISDA ALF: Katherine Tew Darras Opening Remarks
ISDA Annual Legal Forum London, February 11, 2026 Opening Remarks Katherine Tew Darras ISDA General Counsel Good morning and welcome to ISDA’s Annual Legal Forum. Thank you for joining us today and thanks to our platinum sponsors – Cleary...
Maintaining Focus on Basel III Endgame Recalibration
In its original form, the US Basel III endgame proposal would have resulted in disproportionate increases in capital for trading book activities, forcing banks to make difficult choices about their participation in certain businesses. After two-and-a-half years, a revised proposal...