FRTB: a work in progress
Banks cannot wait for clarification but must forge ahead
When the Basel Committee on Banking Supervision completed its Fundamental review of the trading book (FRTB) in January 2016, the hard work began for the banks. In practice, the final rules for each jurisdiction have yet to be drafted, and there are still many fine points that need clarifying to facilitate implementation.
At the time of writing, the industry is waiting on a frequently asked questions (FAQ) document from the Basel Committee to provide some of that clarification. Even a brief and incomplete list of questions is daunting. Most important is the profit-and-loss (P&L) attribution test, which decides whether banks can use their own internal models to calculate market risk, or whether they must revert to the regulator-prescribed sensitivity-based approach (SBA). Industry studies suggest the SBA will lead to a capital charge 2–6.2 times higher than the internal models method. Yet the final FRTB standards presented two different ways of carrying out the P&L attribution test, and banks need to know which one will apply.
Further questions surround the concept of immaterial risks mentioned in FRTB. Banks face a capital add-on for any risks they are unable to model due to lack of data. Often those risks are a very small part of the bank’s trading book to which they are rarely exposed – hence the lack of data. So banks are hoping that an exemption from calculating capital requirements for risks deemed immaterial could reduce the size of the capital add-ons. But again, the Basel FAQ may shed more light on whether this is acceptable.
Even the raw materials for calculating market risk capital – market prices – are in question. FRTB requires banks to input ‘committed quotes’ into their risk models but, as yet, there is no firm definition of what qualifies as a committed quote.
This question shows how FRTB may extend the reach of prudential regulation beyond the banks themselves. Dealers typically source much of their market risk data from third-party vendors. The cost to the bank if data proves unreliable – potentially, the loss of approval for internal model use and the resulting increase in capital requirements – could be substantial.
Read more articles from the FRTB special report
Vendors are already responding to the challenge and looking to work with clients to ensure a level of data integrity that can pass muster with supervisors. There are also initiatives to pool market risk data among banks, but these must overcome dealers’ natural concerns over sharing proprietary and market-sensitive data with competitors.
The systems needs, even for the standardised SBA, are particularly burdensome for smaller players. The European Commission has consulted on whether to apply FRTB at all to banks with limited trading desk operations, and industry associations report similar concerns among investment banks in emerging markets.
This may prompt smaller players to hesitate before beginning FRTB implementation projects. But with the Basel standards due to enter into force from the beginning of 2019, no-one can afford to wait too long to start their preparations. As several of the contributors to this report outline, the scale of the transformation is considerable. Alongside the trading desks themselves, risk, finance and technology divisions will all be drawn into the mix. Even if we do not yet know every minute detail of the final regulations, banks will need to identify today the tasks they must perform – and the resources required to perform them – to be ready for 2019.
Only users who have a paid subscription or are part of a corporate subscription are able to print or copy content.
To access these options, along with all other subscription benefits, please contact info@risk.net or view our subscription options here: http://subscriptions.risk.net/subscribe
You are currently unable to print this content. Please contact info@risk.net to find out more.
You are currently unable to copy this content. Please contact info@risk.net to find out more.
Copyright Infopro Digital Limited. All rights reserved.
As outlined in our terms and conditions, https://www.infopro-digital.com/terms-and-conditions/subscriptions/ (point 2.4), printing is limited to a single copy.
If you would like to purchase additional rights please email info@risk.net
Copyright Infopro Digital Limited. All rights reserved.
You may share this content using our article tools. As outlined in our terms and conditions, https://www.infopro-digital.com/terms-and-conditions/subscriptions/ (clause 2.4), an Authorised User may only make one copy of the materials for their own personal use. You must also comply with the restrictions in clause 2.5.
If you would like to purchase additional rights please email info@risk.net
More on Regulation
CFTC’s Mersinger wants new rules for vertical silos
Republican commissioner shares Democrats’ concerns about combined FCMs and clearing houses
Adapting FRTB strategies across Apac markets
As Apac banks face FRTB deadlines, MSCI explores the insights from early adopters that can help them align with requirements
Republican SEC may focus on fixed income – Peirce
Commissioner also wants a revival of finders’ exemption, more guidance for UST clearing
Streamlining shareholding disclosure compliance
Shareholding disclosure compliance is increasingly complex due to a global patchwork of regulations and the challenge of managing vast amounts of data
Banks take aim at Gruenberg’s brokered deposit rule
Regulatory lawyers question need to reverse 2020 rulemaking just four years later
Time running out to backload Emir derivatives reporting
Significant slice of legacy trades still not ready for new formats, as October 26 deadline looms
Gensler to stick to Treasury clearing timetable
SEC chief promises to keep up the pressure for done-away trades
Clearing houses fear being classified as Dora third parties
As 2025 deadline looms, CCP and exchange members seek risk information that’s usually deemed confidential