The Basel Committee on Banking Supervision document, Basel III: Finalising post-crisis reforms, published on December 7, 2017, is driven largely by criticism of banks’ internal models and the variability in their results under Pillar 1 capital calculations. It is both legitimate and sensible to try to reduce this variability.
Views nevertheless continue to differ on how this objective can best be achieved. We believe the new framework for credit risk capital in particular will need careful
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