ISDA, GFMA & IIF Further Response To The BCBS Consultative Document "The Non-Internal Model Method For Capitalizing Counterparty Credit Risk Exposures"

The Associations welcome the Basel Committee’s Paper as a significant step in the right direction and believe that the proposed non-internal model method (NIMM) framework has great potential. As an alternative to the current exposure method (CEM), it is clear that NIMM performs significantly better as a measure of exposure.

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