A-IRB is overly prescriptive, say US banks

“With credit risk, data is plentiful and increasingly available, quantification techniques are well developed, and the market practices to both price and hedge risk are improving every day. Yet with all this, the ANPR continues to provide a great deal of prescription that in total arrives at a capital results that are too conservative,” said Massachusetts-based FleetBoston Financial in its comment letter.

In contrast, the determination of operational risk, a discipline very much in its infancy

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