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Response to consultation Paper on draft RTS on criteria for assessing risk factors modellability under the IMA
Go backQ5. Do you see any problems with requiring that institutions are allowed to use data from external data providers as input to the modellability assessment only where the external data providers are regularly subject to an independent audit (independent of whether the price is shared with the institution or not)? If so, please describe them thoroughly (i.e. for which data providers and the reasons for it).
see the attached fileQ6. Do you have any proposals on additional specifications that could be included in the legal text in order to ensure that verifiable prices provided by third-party vendors meet the requirements of this Regulation?
see the attached fileQ7. How relevant are the provisions outlined above for your institution? How many and which curves, surfaces or cubes are (planned to be) represented by a mathematical function with function parameters chosen as risk factors in your (future) internal model?
see the attached fileQ8. Do you have a preference for any of the options outlined above? For which reasons? Please motivate your response.
see the attached fileQ9. Do you consider any of the options outlined above as impossible or impractical? For which reasons? Please motivate your response.
see the attached fileQ10. Do you have alternative proposals to define the consequence on the modellability of the parameters where some buckets of a curve, surface or cube are modellable whilst others are nonmodellable?
see the attached fileQ11. Do you intend to apply paragraph 4? If so, for which risk factors will it be relevant? Do you expect any implementation issues related to it? Please explain expected issues thoroughly.
see the attached fileQ12. Do you agree with the outlined methodology for the assessment of modellability of risk factors? If not, please explain why.
see the attached fileQ13. Do you expect any problems for the modellability assessment arising from the upcoming benchmark rate transition that could be addressed via this regulation? If so, please provide a thorough description and potential solutions if any
see the attached fileQ14. How do you intend to integrate the risk factor modellability assessment (i.e. RFET) into the processes of your institution? Do you expect those data to be used for the purpose of the RFET only or do you think those data would increase the data availability used e.g. for the calibration of your internal model (under para 31.26 of 2019 Basel rules)? What percentage of data used for the RFET do you think will be used also for the calibration of your internal model?
see the attached fileName of organisation
Intesa Sanpaolo