While there are certain continuous threads about contending with FRTB, each region has its unique challenges and views on best practices.
Implementation timelines are top of mind in APAC
Sometimes being first on the scene is advantageous, but in the case of FRTB, the first mover advantage is slightly more nuanced. The repeated postponement of deadlines and misalignment between major jurisdictions was cited as a main challenge for firms during numerous conversations.
Overall, Hong Kong, Taiwan, and Singapore are seen as ahead in terms of their implementation timeline with a reporting phase set to start from July 2024. Participants noted banks will effectively need to be fully ready by that date, as many of these jurisdictions have highly granular reporting requirements.
On the other hand, Australia has a much later implementation date of 2026. Nevertheless, banks in the region have been working on FRTB for many years and stand ready for reviewing the rules expected to be published in the first half of next year.
Jurisdictional differences for data and analytics
The baseline version of FRTB published by the Basel Committee on Banking Supervision (BCBS) is a global guideline but not legally binding. Capital requirements are up to local regulators and legislators, who adapt the rule based on regional considerations, resulting in each jurisdiction having its own particular version of FRTB. This can be particularly challenging for banks that have operations in multiple countries in Asia and outside of the region, as the requirements may not be consistent from country to country. For example, different jurisdictions have different rules for bucketing risk factors for the Standardized Approach, particularly around credit spread risk factors.
Different jurisdictions also have different rules and expectations around the look-through approach for indices and funds. Look-through requirements have been a challenge for banks in general, as they require holdings data that can be difficult to obtain, especially for funds. This was covered in more detail in the first blog in our series, here. Thus, banks have been asking regulators for alternatives to full look-through.
The Basel framework allows banks to bypass looking through for indices that are diverse enough (no single constituent has a weight greater than 25%, and other, more complex criteria). However, during the discussion, it was noted that some of the largest indices in APAC do not satisfy these opt-out requirements. As many banks hold and write derivatives on funds linked to these indices, they would still be required to look through.
Another point of discussion related to the use of ratings. In Asia, there are local rating agencies for local instruments as well as the big three rating agencies for everything else. Deciding which ratings to use or which ratings to use in combination was a major point of contention. In connection with this, there was significant interest in the U.S. Notice Purpose of Rulemaking, which bypasses the use of ratings altogether, as banks speculated on whether such an approach could take hold globally.
Banks looking to navigate these differences have a tough road ahead and having a strong data set and accompanying analytics will be imperative as they work to satisfy cross-jurisdictional needs.
To take the Internal Model Approach, or not?
In APAC, there is an expectation that most of the larger banks should apply for the Internal Model Approach (IMA), for both business and market positioning reasons. However, getting the IMA model approved by regulators is complex so many banks have expressed concerns they won’t be ready for the initial deadlines but may consider going the IMA route at a later stage. The current consensus is for banks to review IMA on a desk-by-desk basis.
The Risk Factor Eligibility Test (RFET) creates another hurdle, specific to the APAC region. Unlike their counterparts in Europe, participants noted fixed income surpasses derivatives as being the most challenging asset class to pass the Risk Factor Eligibility Test.
Additionally, plausibility around data pooling has decreased. In an effort to establish a more extensive range of modellable risk factors, banks have historically thought about creating region-specific consortiums, however, participants noted that this is no longer regarded as a viable option since it would benefit mainly the smaller institutions and leave the largest one reluctant to share anonymized trade data. Instead, banks will look to their own observations (trades and quotes) and will seek vendor data to supplement what is aggregated internally.
How Bloomberg can help
To help banks manage existing FRTB requirements and meet upcoming compliance deadlines, Bloomberg provides both enterprise data and analytical solutions. Whether firms require FRTB-ready market data, a reliable risk analytics engine or a full end-to-end workflow, Bloomberg can customize a package to meet specific requirements across all major jurisdictions.
Bloomberg’s FRTB Data Solution provides scalable, enterprise access to high-quality, complete data and helps banks to gain approval for their models while minimizing add-on capital charges. This solution covers both the Standard Approach (Bucketing of Risk Factors) and the Internal Model Approach (Risk Factor Eligibility Test).
Bloomberg’s Multi-Asset Risk System (MARS) Market Risk solution offers a suite of risk analytics and calculations for the entire FRTB workflow. With market-leading data at its core, MARS Market Risk provides banks with the necessary tools to accurately model multi-asset portfolios and meet regulatory risk management and reporting needs.
To hear more FRTB implementation and data challenges, view our recent webinar, FRTB – the Final Countdown or read the first blog in our FRTB roundtable series.
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