Irish Banking Federation

The consultation paper states as a conclusion that the data waiver should not be available to banks once five years has elapsed since an initial IRB permission is granted to the bank. We believe that this conclusion is inappropriate in some cases, even where a bank has had IRB permissions for five or more years. A bank may be rolling out IRB on portfolios temporarily exempted from the IRB approach or on portfolios newly acquired or in respect of new business. In such cases, the waiver should be afforded to institutions with IRB permissions in excess of five years on the same basis as they are afforded to institutions with no or with permissions less than five years. This should only apply to further rollout of the IRB approach and should not apply where an IRB approach is already in use. The proposal, as it stands, places inappropriate barriers to further rollout of IRB approaches on banks with already existing IRB permissions.
Ali Ugur