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The IACPM is a non-profit organization dedicated to advancing the practice of credit portfolio management.

IACPM Comment Letters to Regulators

“Reducing variation in credit risk-weighted assets - constraints on the use of internal model approaches”


“Revisions to the Standardized Approach for Credit Risk” (BCBS d307)



APRA - Revisions to the prudential framework for securitisation


Criteria for identifying simple, transparent and comparable securitizations (D304)


“Guidance on accounting for expected credit losses”


“Revisions to the Basel Securitization Framework - second consultative document” (BCBS269)


“Revisions to the Basel Securitization Framework” (BCBS236)


"Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring" -- Notice of proposed rule making by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation.


“Fundamental Review of the Trading Book: A Revised Market Risk Framework” (BCBS265)


Credit Risk Retention Re-Proposal (SEC 34-70277)


“Financial Instruments: Expected Credit Losses” (IASB Exposure Draft ED/2013/3)


"Recognizing the Cost of Credit Protection Purchased" (BCBS245)


“Capital Requirements for Bank Exposures to Central Counterparties” (BCBS227)


SEC's proposed rule 127B


“Cumulative effects of Capital and Liquidity Proposals ("Basel III") on the Cost of Corporate Credit”