Its proposal looks very much inspired from prudential banking regulation, with a strong governance around the use of models like in the CRR (Regulation EU 575/2013) that applies to credit institutions, and recently amended in light of the Basel III reform. Such views do not take into account the profile of investment funds.

Moreover, the introduction of a specific governance on IMMV represents an unnecessary burden for asset managers using an already approved model (ISDA SIMM): approval by the NCA, monitoring, backtesting.

View the ALFI response.