IFRS 9 Modeling Challenges

From Open Risk Manual

IFRS 9 Modelling Challenges

This is a list of specific technical areas that pose a challenge in the development and validation of robust IFRS 9 / CECL models. Given the wide scope of the Standard and the varying degree of prior experience of firms the list is split in several segments according to the starting point. High level regulatory guidance on the subject is provided in [1] and [2]

The focus of the list is on modelling challenges and not the broader resourcing, provisioning, governance etc. challenges associated with implementing an IFRS 9 programme.

Data availability and data quality challenges are in scope, as they typically have very significant impact on model development

Starting Point: All

Challenge Nature Relevant Entries
Adequate selection of Credit Risk drivers, including impact of underwriting standards
Objective basis for the grouping of exposures while retaining SICR sensitivity
Coherence of SICR methodology with credit rating and ECL estimation
ECL Approaches for low default portfolios
ECL Approaches for new products with limited history
Number of scenarios in ECL estimation
Selection of all relevant forward looking information in ECL estimation
Addressing the impact of sovereign events (Rating Cap)
Capturing model risk, e.g., when multiple approaches are available

Starting Point: Advanced IRB Basel Models

Challenge Nature Relevant Entries
Conversion from prudential to best estimate
Conversion from one-year to multi-period
Conversion from TTC to PIT

Starting Point: Standardized Basel Models

Challenge Nature Relevant Entries

Starting Point: Other

Challenge Nature Relevant Entries

References

  1. Guidance on credit risk and accounting for expected credit losses BIS-D350, Dec 2015
  2. EBA/GL/2017/06