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ABN AMRO Bank NV

Yes, the understanding of accounting value within the range is an indicator for assessing the down side uncertainty.
The definition of upside uncertainty appears to be suitable, but further clarification (including an example) would be good.
The split is practical.
Exotic should be defined in more detail. Further, there could be an intermediate category, such as flow exotics". This category would for instance include digital IR caps or FX barrier options. Arguably, the model risk residing in flow exotics is lower than in exotics, and institutions might want to reflect this in their treatments of the model risk AVAs."
Not currently significant.
Not applicable.
60 characters is too limited for a meaningful description. These columns should be removed from the framework.
Instructions are clear.
No
Edwin van Heusden
A