Response to consultation on amending RTS on CVA proxy spread

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Question 1: Do stakeholders agree with the amendment?

Please see attached response letter

Question 2: Could stakeholders elaborate on the type of alternative credit quality assessments to be performed and on the precise cases or type of counterparties, for which such alternative credit quality assessments would be absolutely necessary, in particular, where relevant, with reference to accounting CVA treatment?

Please see attached response letter

Question 3: Do stakeholders agree with the amendment? Do stakeholders consider that an additional condition is necessary on rating?

Please see attached response letter

Q4: In case the approaches proposed to correct the negative gamma and/or the behavioural factors are deemed to be too burdensome, what simpler alternative adjustments may be applied to correct the modified duration?

Please see attached response letter

Question 5: Could stakeholders elaborate on cases (types of counterparties, business activities) where this adjustment would have a particularly significant impact and on the rationale for performing the adjustment in such cases?

Please see attached response letter

Question 6: What are stakeholders’ views on proposed Options A and B?

Please see attached response letter

Question 7: Do stakeholders consider that other amendments to the RTS would need to be performed as part of this revision? Please provide rationale.

Please see attached response letter

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Name of organisation

ISDA-AFME