On September 4, 2020, ISDA submitted a response to a consultation by the European Banking Authority (EBA) on the calculation of the stress scenario risk measure.
One of the key features of the Fundamental Review of the Trading Book is the classification of risk factors that are included in risk measurement models of banks as modellable or non-modellable. As a result, the standards stipulate that institutions must calculate a separate stress scenario risk measure for each non-modellable risk factor (or non-modellable bucket).
This consultation sets out the methodologies that institutions are required to use for the purpose of determining the extreme scenario of future shock that, when applied to the non-modellable risk factor, provides the stress scenario risk measure. Setting out a clear methodology is deemed necessary to ensure a level playing field among institutions in the European Union.
The industry recognizes the EBA’s substantial efforts in developing regulatory standards on the calculation of the stress scenario risk measure for non-modellable risk factors as proposed in this consultation. However, there are concerns that the prescriptive nature of this regulatory technical standard could lead to fragmentation. We believe further revisions are necessary to improve the operational complexity, and demonstrate how a high-level principles-based approach would provide a more proportionate alternative.
Documents (1) for Consultation Response on the Calculation of the Stress Scenario Risk Measure
Latest
Steps to a Vibrant Derivatives Market: SOM Remarks
Steps to a Vibrant and Resilient Derivatives Market December 4, 2025 Remarks at the Mediterranean Partnership of Securities Regulators Scott O’Malia ISDA Chief Executive Officer Good afternoon and thank you to the Mediterranean Partnership of Securities Regulators (MPSR) for...
ISDA Response to BoE on Gilt Market Resilience
On November 28, ISDA responded to the Bank of England’s discussion paper on gilt market resilience. ISDA encourages the Bank of England, before introducing any significant policy changes that would affect the functioning of the gilt repo market, to consider...
Addressing Termination Troubles
When Enron announced a shock $618 million loss on October 16, 2001, it took a further 47 days until it filed for bankruptcy. For Bear Stearns, it took 266 days between its bailout of a structured credit fund run by...
ISDA In Review – November 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in November 2025.
