A retroactive implementation of elements such as the definition of default would be almost impossible. For new exposures the data series could be limited to even less than two years. In this context, possible interactions with the use of data waivers (as per the RTS developed under Art. 180 CRR) should be taken into account to avoid situations leading to withdrawal of authorisation for an existing IRB.
The numerous changes of the models will be significant which will also lead to a wave of re-authorisations from the authorities, and there is no clear indication of how the EBA envisages to deal with this situation. A solution could be to instead treat certain of these aspects under the SREP. Finally an implementation by 2018 concretely means that institutions shall have to be ready by 2017, limiting further the implementation timeframe.
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