On January 19, the International Swaps and Derivatives Association, Inc. (“ISDA”), Global Financial Markets Association (“GFMA”) and the Institute of International Finance ("IIF") (together “the Associations”), submitted a further industry comment letter on proposed revisions to the Fundamental Review of the Trading Book regarding the capturing of market illiquidity, the treatment of credit, the trading book/banking book boundary, the model independent approval process, disclosure requirements and floors. From an industry standpoint, factoring in market liquidity and the Standardized Approach are the most pressing topics, followed by the treatment of credit and the model independent approval process. This letter discusses the various components of the Associations’ alternative proposals to the Basel Committee on Banking Supervision’s framework.

**Updated on January 22**