Fundamental Review of the Trading Book (FRTB): A Deep Dive into US, UK and EU Rulemaking and Implementation

Abstract

The Fundamental Review of the Trading Book (FRTB) is a comprehensive Basel III framework introduced to overhaul market risk capital requirements during the 2007–2009 financial crisis. The framework includes two main approaches for measuring market risk capital: a more risk-sensitive Internal Models Approach (IMA) for banks that obtain supervisory approval and a revised Standardised Approach (SA) that applies granular risk-weighted sensitivities for all banks. This framework has global significance, and its implementation is underway across major jurisdictions. However, the United States, European Union and United Kingdom have taken somewhat divergent paths and timelines in adopting FRTB, reflecting local regulatory priorities and constraints. This document provides a condensed analysis of FRTB’s framework, comparing US, UK and EU regulatory approaches, methodologies and model approval processes. It also discusses the anticipated impact on large international banks, including changes in risk-weighted assets and capital requirements. It evaluates whether FRTB’s benefits in risk management and financial stability justify the compliance costs. The findings underscore FRTB’s role in strengthening market risk regulation while highlighting the importance of coordinated implementation and fine-tuning to address industry concerns. Key innovations of FRTB include: desk-level model approvals, a rigorous Profit & Loss Attribution (PLAT) test to ensure model accuracy, a Default Risk Charge (DRC) for jump-to-default risks and capital add-ons for Non-Modellable Risk Factors (NMRFs). Since BCBS finalized FRTB standards (as part of the Basel III “final reforms” in 2017–2019) [5], jurisdictions have moved at different paces to implement them.