Fundamentally fraught: the chaotic last weeks of the FRTB
Quick fixes should have no place in a sweeping three-year reform project
So, after more than three years of work on new trading book capital rules, this is how it ends: a confused, chaotic sprint to meet an arbitrary deadline; vital questions left unanswered; impacts unknown.
That's how the banks see it anyway. Of course, if you listen to banks, this is how every rule-making process ends – so the furore about the Fundamental review of the trading book (FRTB) might at first appear to be the usual case of a frustrated industry making a final, desperate roll of the dice. What's different this time is that some of the complaints are echoed by regulators who have been involved in the process.
A final round of changes to the FRTB was made when the Basel Committee on Banking Supervision belatedly decided to run a fourth quantitative impact study (QIS) in July. This, in itself, was evidence of the pressure regulators were under – it would have been more normal to consult on the changes, then to issue QIS instructions. But with the committee apparently under instructions to finish the rules this year, wholesale changes had to be made with no public consultation.
So, out went the asymmetric treatment of correlations – an element of the draft standardised approach that had produced a huge capital uplift relative to modelled numbers in the third QIS. In its place suddenly appeared an add-on for residual risk, in the form of a 1% charge on the notional of more exotic products. It had more or less the same effect as the mechanism it replaced – banks say it ended up accounting for almost half of the standardised charge. Where did the add-on come from? One regulator says: "There are people at the committee level that are very fearful of models. So they looked at this and said 'One percent of notional: why not? This is all the exotic stuff: what are they doing in this space anyway?' It was a quick and easy fix."
Based on the results of the fourth QIS, the impact of the add-on is expected to be scaled down – regulators say it should ultimately account for around 10% of the standardised capital total. Another quick fix.
But the FRTB was not supposed to be about quick fixes. It was an attempt to replace Basel 2.5 – an entirely necessary post-crisis repair job – with a coherent set of rules. Conceptually, a lot of it makes sense, and even banks would probably concede regulators are taking aim at the right targets, but there was a lot to do. And the banks are right to complain it has been rushed.
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 Risk management
Intraday pricing: fixed income’s next frontier
With firms looking to price fixed income securities on an intraday basis, specialist pricing providers such as LSEG help address cost, complexity and time-to-market challenges
Tech and data fragmentation irks enterprise risk managers
Risk Benchmarking: Often at the mercy of decisions made by other parts of the bank, ERM heads gripe at disparate systems, poor UX and reporting gaps
At bigger banks, enterprise risk owns scenario frameworks
Risk Benchmarking research finds ERM teams tasked with providing effective challenge on scenario construction across risk silos
Asian firms waiting on exemptions from UST clearing mandate
Hoping for relief on extraterritoriality, 51% of Apac firms have yet to start compliance programmes
HSBC’s Orion sees cash leg challenge to tokenised bonds
Tradeweb and others agree more work needed before atomic settlement is achieved
Month-long power glitch hits key Apac trade surveillance tool
Nasdaq’s alert functions were restored, but users say testing and calibration tools still disrupted
Why resilience goes beyond risk at StanChart
Risk Live: Reliability is “a business goal” that can involve difficult trade-offs, says Americas CEO DeFilippo
Agentic risk management could arrive ‘sooner than we think’
Risk Live: Models are capable, but banks lack platform and governance to safely run agentic systems