Response to consultation on RTS on the specification of the nature, severity and duration of an economic downturn

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Question 1: Do you have any concerns around the workability of the suggested approach (e.g. data availability issues)?

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Question 2: Do you see any significant differences between LGD and CF estimates which should be reflected in the approach used for the economic downturn identification?

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Question 3: Is the concept of model components sufficiently clear from the RTS? Do you have operational concerns around the proposed model components approach?

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Question 4: Do you have any concerns about the complexity around the dependency approach proposed for the identification of the nature of an economic downturn? Is it sufficiently operational?

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Question 5: Do you agree with the proposed approach for computing the time series of the realised model component referring to the realisation of the model component rather than to the year of default?

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Question 6: Do you envisage any situation where a one year duration is not suitable of capturing the economic downturn at the economic factor level?

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Question 7: Do you have any concerns about the approach proposed for the identification of the severity of an economic downturn? Is it sufficiently operational?

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Question 8: Do you think that more details should be included in Article 2(3) for the purposes of the evaluating whether sufficiently severe conditions are observed in the past?

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Question 9: Do you think Article 6 should pin down the steps for the joint impact analysis described in this text box?

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Question 10: Do you have any concern around the proposed approach about the identification of the final downturn scenario?

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Question 11: Do you see any issue with the estimation of the model components for downturn periods which are not in the data base of the institution (e.g. in step 3 the case where the estimation of cure rate for 2001 is performed on the basis of the dependency assessment described in Article 3(2)(e) and (f))?

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Question 12: Do you think the same approach for the identification of the final downturn scenario proposed in this text box for LGD could be adopted also for the purpose of downturn CF estimation?

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Question 13: Do you think the draft GLs should describe in more detail the downturn adjustment methodology?

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Question 14: Do you think simpler alternative approaches for downturn adjustment should be considered in the spirit of proportionality?

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Question 15: What is your view on the alternative approaches? Please provide your rationale.

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Question 16: Which approach are you currently using for estimating downturn LGDs?

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Name of organisation

Institute of International Finance