The BSA has responded briefly to the BCBS CP on reducing variation in credit risk- weighted assets by constraining the use of internal model approaches. We strongly support the preliminary input and comprehensive response from the EACB. We caution that the BCBS' proposals have the potential to inflict considerable ( and avoidable) damage on the mortgage and housing markets, and doubt they are compatible with the BCBS' mandate from the G-20 GHOS not to increase overall capital requirements significantly.
Read the full response .