On October 22, 2020, ISDA submitted a response to a consultation by the European Banking Authority (EBA) on the requirements of the internal default risk model to estimate default probabilities and losses given default.
Institutions using an alternative internal model to compute own funds requirements for market risk and holding positions in traded debt and equity instruments through trading desks covered by internal models approach permission are required to additionally compute an own funds requirement using an internal default risk model.
One of the requirements under the internal default risk model is for institutions to be capable of modelling the default of individual issuers, as well as the simultaneous default of multiple issuers, and computing the impact of those defaults on the market values of the positions that are included in the scope of that model. This consultation specifies the requirements that an institution’s internal methodology or external sources are to fulfil for estimating default probabilities and losses given default.
The industry appreciates the EBA’s efforts in developing regulatory standards for the sources used to develop default probabilities and losses given default. However, there are concerns about using the internal rating-based approach, which was built and designed for banking book activities. Utilizing this approach for market risk could lead to model design inconsistencies.
Documents (1) for Consultation Response on Internal Default Risk Model Requirements
Latest
US FX Derivatives Review
ISDA has expanded its SwapsInfo website to include data on US foreign exchange (FX) derivatives, extending the platform's coverage beyond interest rate and credit derivatives to a third over-the-counter derivatives asset class. The US FX Derivatives Review covers trading activity...
Response to FCA on Post-trade Transparency
On October 16, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/30. While the consultation is principally focused on cash equity market structure and transparency, ISDA responded to questions on the potential inclusion of equity swaps in the scope...
Efficiency is Vital to Delivering Resilience
With less than three months to go until implementation of US Treasury clearing begins at the end of this year, it’s critical that the mandate is safely implemented without compromising market efficiency. This represents a huge change in market structure,...
ISDA In Review – September 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2026.
