The Clearing House (TCH) along with SIMFA, the FMA, and the FSR (collectively, Associations), submitted a comment letter to the BCBS in response to its consultative document on the Standardized Measurement Approach to Operational Risk. In the letter, the Associations affirmed their support for the proposed withdrawal of the Advanced Measurement Approach framework in favor of a more stable and less complex standardized measure of operational risk that both promotes greater comparability and is appropriately risk-sensitive. The letter also offers recommendations on a range of small but effective changes that would make the standardized measurement approach more meaningfully risk-sensitive and more reflective of the current operational risk environment at each bank. The letter also asks the Basel Committee to provide the empirical basis for the most recent calibration of the framework and encourages the Committee to regularly perform quantitative impact studies and recalibrate the framework as necessary and appropriate based on those results to ensure the assumptions remain current and accurately reflect banks’ risk profiles.
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