Status: Draft -- Not PublishedWill be live at 12/31/2014 00:00
Joint Associations' response to the proposed revisions to the simpler approaches for operational risk
Wednesday, December 31, 2014
The IIF together with GFMA, ISDA and TCH (together, the Associations) responded to the proposed revisions to the simpler approaches for operational risk.' The Associations expressed strong support to the Basel WGOR's objectives to address issues and weaknesses in the current simple approaches for operational risk, as the industry shares the same goal of having a more robust operational risk regulatory capital framework.' However, the Associations are of the view that there is still room to enhance the risk sensitivity of the proposed new framework relative to the existing one, which is a stated objective of the proposed revisions. The Associations also criticized the proposed revisions' emphasis on firm size without taking into account the quality of a firm's operational risk management.' The Associations' response included some ideas for the proposed revisions that the Basel Committee's Working Group on Operational Risk may wish to consider as it continues to do its analytical work.