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The EBF supports the objective of the draft Guidelines, to reduce unjustified variability in the IRB Approach. EBF understands that the EBA considers these clarifications and harmonisation necessary in order to achieve comparability of risk parameters estimated on the basis of internal models and to restore trust in these models by market participants while at the same time preserving risk sensitivity of capital requirements.
One important observation from the Public Hearing was the depth of analysis and consideration given to the draft Guidelines prior to their publication. It is clear that alternatives have been considered. It is also clear that choices have been made to develop and progress the necessary harmonisation in a considered manner. EBF asks, however, that consideration is provided to describing more clearly the choices afforded to banks in modelling and the role of the supervisor in evaluating or providing constraints on these choices. Already, individual supervisors are imposing the draft Guidelines as prerequisites to model and material change proposals often with strongly prescriptive interpretations that EBF‘s member banks believe are contrary to those intended. Without greater detail on the context of the Guidelines, there is a significant risk that they might inadvertently promote greater divergence in modelling outcomes for similar risks. Much of our feedback, seeks to draw out this clarity within the finalised Guidelines.
EBF understands that the harmonisation of internal modelling practices requires a thorough analysis of current practices. Nevertheless, EBF would also like to draw the attention of the EBA to the aspect of cost involved. The many triggers introduced for re-development, reestimation and re-calibration of internal models indirectly raises questions about how often this should be made and the burden to constantly recalibrate. The aspect of cost should be taken into account and eventually consider annual reviews instead of constant recalibrations. The results of the impact assessment currently underway should be carefully examined in order to factor in the cost of changes as a relevant variable. In all cases, the objective of MoC, of re-calibrations and of re-developments should be to ensure the adequacy of regulatory capital and not be used to require model optimisation by a supervisor. The optimality of a model should be a choice for an individual bank and here cost versus benefits will be considered.
One possibility to limit the impact on cost would be to apply the Guidelines only to future models. If this is not the case, then EBF would ask for adequate phase-in periods in order to avoid redeveloping a huge number of models. Some sense of proportionality should be introduced in the final version of the Guidelines or it could end up that all models will need to be reworked.
As regards the timeline for implementation EBF would like to draw to EBA’s attention the fact that many concurrent changes are being published about internal models (e.g. “RTS on IRB assessment methodology”, “RTS on materiality threshold for past due exposures”, “GL on the application of the definition of default”, “RTS on the nature, severity and duration of economic downturn”). Somehow these Guidelines wrap up many of those changes thus there should be a comprehensive understanding of them all before implementation. The date of application from 1 January 2021 seems to be challenging.
In order to achieve reduction in the unjustified variability it is important that the guidelines are adhered to by competent authorities without imposing stricter requirements. This is, obviously, an implementation issue, but we want to highlight it for the sake of harmonisation.