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February 05, 2025 Content Type Case study

ISDA SIMM Model Documentation for Japanese Bank submission to NFA

February 05, 2025 Content Type Case study

 

 

 

Client

 

Japanese Bank

 

Objective

 

To help a Japanese bank complete ISDA SIMM Model Documentation under tight deadline for submission to the NFA.

 

Crisil's Solution

 

  • Quickly formed a four-member team that performed a comprehensive analysis of guidelines provided by different regulatory/governing bodies (ISDA, NFA, SR-11-07)
  • Developed two comprehensive reports (150+ pages each), detailing model development and model validation
  • Identified and addressed additional tests and remediation areas, including stress testing, ongoing monitoring, governance streamlining, etc.
  • Generated additional supporting documents, such as Clean P&L Generation Methodology, as part of the package
  • Performed various stress tests that enhanced confidence in the model and its implementation

Challenges

 

  • Intermediate steps calculated using different systems and multiple documents that were not in line with SR-11-07 and NFA/regulatory guidelines
  • Short execution time due to a tight regulatory deadline

 

Client Impact

 

  • The team delivered high-quality, regulator-ready documents within the planned timeline and budget 
  • Generated more than 40% savings for the client by executing the project from Crisil offshore office

 

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