Lloyds Banking Group

We view this as positive
There should be a level playing field for all banks. The use of 2 years data should be allowed on a rating system/portfolio basis rather than limited to firms who have held IRB waivers for less than 5 years. This will facilitate remaining IRB roll-out across the industry, as well as increasing flexibility to use the most relevant data when building models which is a good thing. (Article 7)
LBG is supportive of the principle to apply conservatism to compensate for the uncertainty arising from the use of a short data series. However, a distinction should be made between those portfolios where there is a lack of data, and those portfolios where older data is deemed less relevant. (Article 6b)
Chris Davies