Part of the 40-article FRTB Standardised Approach guide.
Featured answer: Regulatory sensitivities should be explainable relative to desk Greeks even when definitions, shocks and granularity differ. This distinction matters for capital accuracy, risk interpretation and the evidence a supervisor or independent reviewer should expect.
The Fundamental Review of the Trading Book is easier to understand when each calculation is treated as an ordered chain rather than an isolated formula. This article explains the regulatory idea, the operational sequence and the controls that make the result defensible.
Why this FRTB topic matters
Regulatory sensitivities should be explainable relative to desk Greeks even when definitions, shocks and granularity differ.
A reliable implementation must connect the economic position to the exact regulatory risk factor, preserve units and signs, apply the effective rule set and expose every permitted offset. The final capital number is only as reliable as that chain.
The regulatory logic
Bridge valuation source, bump size, market-data snapshot, factor transformation, currency and aggregation step by step.
The calculation should always be read as a sequence: define the exposure, calculate the relevant measure, apply the prescribed calibration, recognise only permitted offsets and retain enough detail to reproduce the result. Numerical parameters must come from the rulebook and jurisdictional version effective for the institution.
A practical way to think about it
Desk DV01 may be reported by curve node while FRTB sensitivity uses prescribed tenors, creating explainable interpolation differences.
This example is conceptual rather than a substitute for a regulated calculation. Its purpose is to show where judgement, data and aggregation enter the process, and why economic hedging does not automatically create the same regulatory offset.
Step-by-step implementation
- Confirm scope and regulatory classification before calculating any sensitivity or capital amount.
- Identify the valuation risk drivers and map them to the prescribed regulatory risk factors.
- Calculate measures using controlled market data, valuation models, units and sign conventions.
- Apply the current jurisdictional risk weights, correlations, buckets and special treatments.
- Aggregate at factor, bucket, risk-class and total-capital level while retaining the audit trail.
- Reconcile results, investigate exceptions and approve the run under the bank control framework.
Controls that make the result defensible
Set tolerance by product and risk class, classify breaks and retain trader/risk sign-off for material differences.
- Completeness: every in-scope position reaches exactly the required capital components.
- Accuracy: sensitivities, mappings, parameters and aggregation are independently testable.
- Timeliness: market data, reference data and regulatory versions are effective for the run date.
- Explainability: material capital movements can be traced to economic or controlled data changes.
Common implementation mistakes
Demanding exact equality can be as misleading as accepting unexplained differences; the goal is controlled explainability.
A useful review question is whether a knowledgeable person could reproduce the treatment from the trade terms, market data, regulatory mapping and versioned parameter set without undocumented judgement. If not, the process is not yet production-grade.
Key takeaways
- Regulatory sensitivities should be explainable relative to desk Greeks even when definitions, shocks and granularity differ.
- FRTB permits diversification only through its defined hierarchy.
- Mapping, units and product coverage are as important as the final aggregation formula.
- Local rules and effective dates must be verified before using any numerical calibration.
Frequently asked questions
Is this relevant only to banks using internal models?
No. The standardised approach is a standalone capital methodology, a fallback and an important benchmark even where internal models are used.
Can a bank use its own correlations or risk weights?
Not for the regulatory standardised calculation unless the applicable local rule explicitly permits an alternative. Prescribed parameters are central to comparability.
Does good economic hedging always remove capital?
No. Recognition depends on regulatory risk-factor identity, bucket structure, correlations and component-specific netting rules.
Conclusion
Regulatory sensitivities should be explainable relative to desk Greeks even when definitions, shocks and granularity differ. The durable implementation principle is simple: classify correctly, measure consistently, apply the prescribed framework exactly and make every material judgement traceable.
Primary sources
- Basel Committee, MAR21 - Standardised approach: sensitivities-based method
- European Banking Authority, Market, counterparty and CVA risk
Related FRTB reading
Educational material, not legal, regulatory or investment advice. Verify local law, technical standards and effective dates before implementation.