On June 20, ISDA, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) submitted the industry response to the Basel Committee on Banking Supervision’s consultation on proposed revisions to the market risk framework (known as the Fundamental Review of the Trading Book (FRTB)).  The changes proposed in the consultation improve the FRTB’s operational robustness, mitigate potentially adverse impacts, and address many of the issues with the FRTB’s initial calibration, particularly for the standard rules.

The revised standardised approach (SA) addresses many shortcomings of the earlier standard. However, the industry believes further changes are necessary – in particular on non-modellable risk factors (NMRFs), which remain an area of concern as the associated capital is still excessive.

Click on the PDF below to read the full submission.