The European Banking Authority (EBA) welcomes the entry into force of the new European Banking Package, which implements the final Basel III framework into EU regulation. To ensure a smooth operational implementation of the Banking Package, the EBA encourages institutions and competent authorities to engage in an active dialogue.
In particular, institutions should:
- communicate to their competent authorities the targeted model landscape, in particular following the migration of exposures to the foundation approach (F-IRB) and standard approach. A key aspect is to ensure that rating systems perform adequately on their scope of application;
- assess and categorise changes coming from the implementation of the Capital Requirements Regulation (CRR3) that impact the performance of a rating system according to the EU Commission’s Delegated Regulation on materiality of changes to the IRB approach. On the other hand, changes coming from the implementation of CRR3 that do not impact the performance of a rating system should not be considered under the scope of the Commission’s Delegated Regulation on model change to the IRB approach;
- share with their competent authority an implementation plan on the foreseen modelling updates that are linked to future EBA supervisory products. In this context, modelling updates in relation to credit conversion factor (CCF) parameters (e.g. 12 months fixed horizon reference date) may not need to be prioritised until the date of application of the EBA Guidelines on IRB-CCF.
