Joint Associations' Response to the Proposed Revisions to the BCBS Standardized Approach for Credit Risk

The IIF, GFMA and IACPM responded to the proposed revisions to the credit risk standardized approach (SA) issued by the BCBS on December 2014.'  In their response, the Associations noted that the end-2015 deadline is not realistic given the issues in the proposed conceptual framework as well as the need to conduct a careful impact analysis to ensure appropriate calibration and impact assessment. ' It was also stressed that credit risk is the cornerstone of the BCBS capital framework and is the most important risk category for most banks, so a more thorough review is warranted. The Associations therefore requested to extend the timeline for this review beyond the planned end-2015 deadline.

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Nevertheless, the Associations expressed their readiness and commitment to assisting the TFSA in completing its work. In this regard, the response offered some general remarks as well as detailed comments and alternatives on specific elements of the proposals. The Associations underscored that the extensive nature of the issues that remain to be resolved as well as the need to measure and test quantitatively many different alternatives reinforce the importance of continuing an active dialogue between the BCBS and the industry as the proposals are further developed.'

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