FRTB implementation runs into hidden obstacles
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COMMENTARY: Facing up to FRTB
The result was published at the start of this year, but the real work has only begun. The Basel Committee's Fundamental review of the trading book (FRTB) was finalised in January this year, and banks around the world must be compliant by the end of 2018; the first reports under the new rules are due a year later.
Given that compressed timescale – just three years, of which one has mostly passed already – it's worrying that so little clarity exists about exactly what compliance with FRTB will mean. A promised FAQ on the rules has yet to appear. No jurisdiction has yet drafted its final rules for FRTB implementation. And many banks are facing a dilemma – either accept the higher capital charges involved in the simpler standardised method, or wait and see for the more advanced approach, and hope the cost and difficulty of implementation are not overwhelming.
There are questions over the exclusion of 'immaterial' risks, which are harder to model; over the abolition of faster methods for calculating market risk sensitivity, such as adjoint algorithmic differentiation or AAD; and most seriously over profit-and-loss attribution.
Time is running out already, and, inevitably, compliance and risk departments will have other unpredicted calls on their time over the next two years, as well as the demands of all the other regulatory changes also coming into force over the same period. It would be no surprise to see a significant increase in hiring between now and mid-2017, as they start to staff up to deal with their many deadlines.
STAT OF THE WEEK
The world's top 12 investment banks have paid out $144 billion in penalties since 2012, which has a double impact: capital is being tied up in reserves and – with regulators on the warpath – banks are also wary of getting into a consortium that may later be cast as anti-competitive.
QUOTE OF THE WEEK
"In global payments, the potential to use distributed ledger technology is relatively high. However, despite statements to the contrary, the existing payment system is expensive but not broken, so competition will be tough" – Alexander Lipton
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