Response to consultation on Guidelines on technical aspects of the management of interest rate risk
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Definition of conditional and unconditional cash flows is also not clear enough. In our opinion it requires presentation of more details – is it only connected to behavioural assumptions on client actions or optionality in products.
In paragraph 4.1 point 18 there are no specific guidelines on CSRBB. Banks do not understand purpose of including CSRBB in IRRBB guidelines.
Calculation methods in annexes are not clear enough due to lack of base assumptions: using base scenario and stress scenarios of earnings measures and economic value measures. It is only included in Paragraph 4.1 point 15.
Other topic of our concern is the text of annex I. On page 46 it is not clear why simple run-off assumption is mentioned. It is measure that is not reasonable/practical to interpret. It is also not mentioned in Annex II.
Question 1: Are the definitions sufficiently clear? If not, please provide concrete suggestions and justify your answer.
Some definition are not clear enough for banking industry. We recommend to explain better the definition of CSRBB. Some examples indicated in this area would be welcomed.Definition of conditional and unconditional cash flows is also not clear enough. In our opinion it requires presentation of more details – is it only connected to behavioural assumptions on client actions or optionality in products.
Question 2: Are the guidelines in section 4.1. regarding the general provisions sufficiently clear? If not, please provide concrete suggestions.
In paragraph 4.1 point 17 and paragraph 4.4.1 point 80.ii - guidelines for IRBB risk originated by interest rate derivatives it is not clear what measures are expected from institutions in that respect. It is also not clear what is understood by loan commitments - loans on forward and/or off balance commitments as overdraft lines.In paragraph 4.1 point 18 there are no specific guidelines on CSRBB. Banks do not understand purpose of including CSRBB in IRRBB guidelines.
Calculation methods in annexes are not clear enough due to lack of base assumptions: using base scenario and stress scenarios of earnings measures and economic value measures. It is only included in Paragraph 4.1 point 15.
Question 3: Do you agree that cash flows from non-performing exposures (NPEs) should be net of provisions and treated as general interest rate sensitive instruments whose modelling should reflect expected cash flows and their timing for the purpose of EV and earnings measures? If not, please provide concrete suggestions and justify your answer.
We agree.Question 4: Are the guidelines in section 4.2. regarding the capital identification, calculation, and allocation sufficiently clear? If not, please provide concrete suggestions and justify your answer.
In our opinion the paragraph 26 point f) of Capital adequacy assessment for IRRBB (the impact of embedded losses) should be clarified. The term “embedded losses” is very broad and general. It may be considered as a part of IFRS9 regime and in another aspects, however it is hard to define in what aspects, in particular in IRRBB. Therefore a clarification or explanation would be welcomed on what does that term means in practise for the purpose of the IRRBB risk measurement.Question 5: Do you agree with the list of elements to be considered for the internal capital allocation in respect of IRRBB to earnings in paragraph 30? If not, please provide concrete suggestions and justify your answer.
We agree.Question 6: Are the guidelines in section 4.3. regarding the governance sufficiently clear? If not, please provide concrete suggestions and justify your answer.
We agree.Question 7: Are the guidelines in section 4.4. regarding the measurement sufficiently clear? If not, please provide concrete suggestions and justify your answer.
The paragraph 82 concerning commercial margins generates confusion in banks. It is not clear as in accompanying documents/treatment of commercial margins chosen option is to leave that choice for institutions. We agree with assumption that bank can choose whether to calculate measures with or without margins – in our opinion both measures should be used. We need to adjust our IT systems for that purposes.Other topic of our concern is the text of annex I. On page 46 it is not clear why simple run-off assumption is mentioned. It is measure that is not reasonable/practical to interpret. It is also not mentioned in Annex II.