FRTB: proxy risk factors may trigger model failures
Swapping non-modellable risk factors for proxies may make it harder to pass P&L attribution test
Using proxies for illiquid risk factors in regulatory capital models might prove to be a double-edged sword – potentially shrinking capital charges for market risk while increasing the possibility of model failures, market participants say.
Non-modellable risk factors (NMRFs), which are those not based on a required number and frequency of past price points, will attract whopping capital add-ons
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