On February 25, ISDA, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) submitted a joint comment letter to the Basel Committee on Banking and Supervision (BCBS) on their final revisions to the credit valuation adjustment (CVA) risk framework. Targeted revisions such as the adjustment of the CVA multiplier, changes to risk weights, the aggregation formula, and the reconsideration of the scope of application to exclude immaterial security finance transactions are significant improvements over the 2017 CVA risk framework. The Associations support the introduction of a scalar for the appropriate calibration of BA-CVA, but believe that further revisions are needed to address design and calibration issues that still exist in the framework and to better reflect the underlying economic risks and incentivize prudent hedging of CVA risk
The letter outlines why CVA is important and summarizes the results of a quantitative impact study conducted by the associations with input from 25 global banks with large trading book activities. Given the potential impact of the proposed CVA framework, the Associations respectfully urge the BCBS to consider and act upon the further revisions highlighted in our key recommendations to avoid any unintended consequences while still achieving the BCBS’s regulatory objectives.
Documents (1) for ISDA/ GFMA/ IIF Response to BCBS Consultation on CVA
Latest
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
Joint Response on Cross-margining
On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
