On 15 November 2018, the European Central Bank (ECB) has published the general topics chapter of its guide to internal models (the Guide), together with a feedback statement to the ECB’s March consultation on the chapter (the Statement). The Guide provides transparency on how the ECB understands the general (i.e. non-model-specific) topics for internal models, in particular for the internal ratings-based (IRB) approach.
Section 2 of the Guide (overarching principles for internal models) covers all Pillar 1 internal models for credit, market and counterparty credit risk, all subsequent sections (implementation of the IRB approach, internal governance, internal validation, internal audit, model use, model change management and third-party involvement) only cover credit risk Pillar 1 models. All other models, including operational risk models, Pillar 2 and managerial models are not included in the scope of the Guide, unless otherwise mentioned.
The Guide should not be construed as going beyond the current existing applicable EU and national law and therefore is not intended to replace, overrule or affect applicable EU and national law.
The accompanying Statement provides data on the respondents to the consultation on the chapter. In chapter 2 of the Statement, there is provided a table recording the ECBs comments to respondents to the consultation on the chapter, and whether steps have been taken to amend the chapter accordingly:
- one amendment has been made to the section on general remarks and introduction;
- one amendment has been made to the section on overarching principles for internal models;
- no amendments have been made to the section on Roll-out and permanent partial use;
- one amendment has been made to the section on internal governance;
- three amendments have been made to the section on internal validation;
- three amendments have been made to the section on internal audits;
- three amendments have been made to the section on model use;
- two amendments have been made to the section on the management of changes to the IRB approach; and
- one amendment has been made to the section on third-party involvement.