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Recital 6

Recital 6

(6)The FRTB standards lay down clear and stringent requirements for non-modellable risk factors (NMRFs) that were introduced in Union law by means of legislative acts and Commission delegated and implementing acts. Due to a very limited adoption worldwide of market risk internal models so far and significant delays in FRTB implementation by major jurisdictions, the development of data solutions from third-party vendors, which would enable credit institutions to classify a smaller number of their risk factors as NMRFs, remains limited. That leads to a significant impact on own funds requirements, which raises concerns that the contribution of NMRFs to the overall own funds requirements calculated using internal models is larger than originally expected. Overall, institutions have perceived the NMRF framework as a key obstacle in developing internal models for market risk. In light of those considerations, other major jurisdictions have simplified their NMRF framework by allowing more risk factors to be capitalised as modellable, under the expected shortfall measure. To preserve a global level playing field and to make the NMRF framework easier to implement, it is necessary to modify the conditions on the number of verifiable prices observations needed for a risk factor to be considered modellable and hence be capitalised under the expected shortfall calculation.

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