The members of the EACB welcome the opportunity to comment on the BCBS review of the trading book.
All in all, we see that the suggestion imply a considerable step up in complexity regarding risk measurement models and connected validation methods. The revised requirements will therefore lead to a significant increase in the implementing cost burden for institutions.
In particular, the implementation of the suggested requirements for internal as well as standard models will lead to significant increase of the required human resources (validation, modelling, risk managers, auditors) and of the IT facilities. ...
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