Submission #1

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Intesa Sanpaolo SpA

Q1. What would you consider to be the main challenges and most time consuming steps involved in using the IRB approach to be able to assign a PD and a LGD to a trading book issuer and the corresponding financial instrument, where such issuer is covered by the existing IRB permission, but no PD or LGD is immediately available under the IRB approach (i.e. they need to be assigned based on the existing IRB approach)? Based on this assessment, please indicate how much time you expect is needed for an IRB approach to assign a PD and a LGD to a specific trading book issuer. Please see the attached document

Upload files Intesa Sanpaolo - Response to DRC EBA_CP_2020_12 - 22 October 2020.pdf

Name of the organization Intesa Sanpaolo SpA