The IACPM has joined the Global Financial Markets Association (GFMA), the International Swaps and Derivatives Association (ISDA) and the Japan Financial Markets Council (JFMC) to comment on the Basel Committee’s Consultative Document “Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches”. The joint association letter addresses concerns that restricting internal modelling will significantly and unnecessarily reduce risk sensitivity which will impact pricing, banking services, and capital.