FSB Proposed Framework for Post-Implementation Evaluation of the Effects of the G20 Financial Regulatory Reforms - Consultation Response

Sep 4, 2026

GARP provides a formal consultation response to the Financial Stability Board on evaluating the effects of G20 financial regulatory reforms after implementation. The response draws on GARP’s five-plus years of experience and its Benchmarking Initiative, which works with major banks to analyze regulatory impacts using objective qualitative and quantitative feedback. It details how GBI developed hypothetical benchmark portfolios, performed validation and analytics for BCBS capital studies, and supports confidential cross-border research through aggregated benchmarking data and a secure disclosure methodology.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages4

Reading Time10 min

AccessFree to download

GARP Consultation Response

Background and Purpose

GBI Development and Validation Work

GBI Capabilities and Outcomes

GBI Offerings for Regulators and Industry Participants

May 7, 2017 Secretariat of the Financial Stability Board Financial Stability Board c/o Bank for International Settlements CH – 4002 Basel Switzerland Re: FSB Proposed Framework for Post-Implementation Evaluation of the Effects of the G20 Financial Regulatory Reforms Consultation Response (FSB Consultation Response) Dear Sir or Madame: The Global Association of Risk Professionals (GARP) 1, reviewed the Financial Stability Board’s (FSB) Proposed Framework for Post-Implementation Evaluation of the Effects of the G20 Financial Regulatory Reforms (Consultation Document), with the objective of responding to the FSB’s request for comments. The comments herein are derived from GARP’s five (5) plus year history analyzing the impacts of proposed G20 regulatory reforms by working directly with most of the world’s largest banks through the GARP Benchmarking Initiative (GBI) . GBI provides, among other things, objective qualitative and quantitative feedback to its participating banks and to global regulators on the impact(s) of proposed regulatory reforms. GARP Benchmarking Initiative (GBI) GBI was developed in response to an idea socialized by Citi a number of years ago wherein it was suggested that banks develop a series of hypothetical benchmark portfolios (HPE) that would represent the various types of trading activities engaged in by internationally active banks. Banks would then run their risk measures against these benchmark portfolios and make the results available to regulators and the public. It was intended to be a way to allow for more transparency around how banks implemented and viewed their risk measures. As GBI progressed, it was asked to perform validation work and then develop objective quantitative and qualitative analytics on the data submitted by banks for the BCBS capital studies over the last 3+ years. A process was developed and agreed to by the banks for conducting the studies. 1 The Global Association of Risk Professionals (GARP), [http://www.garp.org](http://www.garp.org), is a not-for-profit global membership organization dedicated to preparing professionals and organizations to make better-informed risk decisions. The GARP community represents over 150,000 risk management practitioners and researchers from banks, investment management firms, government agencies, academic institutions and corporations from more than 195 countries. GARP's mission is to educate, train and set global standards in financial and energy risk management. The association administers the Financial Risk Manager (FRM®) and Energy Risk Professional (ERP®) exams; certifications recognized and valued by risk professionals worldwide. GARP also helps advance the role of risk management via comprehensive professional education and training for professionals of all levels. GARP does not engage in consulting or lobbying activities. The institutional knowledge GBI has gained by completing over 32 studies to date, and continues to build with each subsequent study, has given GBI a developed and proven capability to efficiently and effectively conduct simple and/or complex studies with speed and accuracy of results. Its work has led to much better and more robust discussions of capital requirements and other issues based on agreed sets of underlying factual data between regulators and financial services industry participants. Further, participating banks are provided aggregated study data allowing them to benchmark themselves against each other while maintaining anonymity, a benefit of material importance to the banks. GBI’s participants now number close to 70 internationally active banks, and continues to expand 2. Over 32 cross-border studies have been completed to date. GBI now enjoys the globally unique position of being the only private organization capable of, and trusted with, engaging in cross-border studies premised on confidential bank data. GBI’s Offerings GBI offers the following benefits for either regulators o

FAQs

What is the document’s purpose?

It is GARP’s response to the FSB request for comments on a proposed framework for post-implementation evaluation of the effects of G20 financial regulatory reforms.

How does GARP’s Benchmarking Initiative (GBI) support the response?

GBI enables objective qualitative and quantitative feedback by having banks run risk measures against hypothetical benchmark portfolios and by producing analytics from submitted bank data.

What advantages does GBI provide for cross-border studies?

GBI offers an infrastructure to address political and jurisdictional challenges, uses master non-disclosure agreements to handle confidentiality, and provides a secure environment for collecting and analyzing confidential data.

Sep 4, 2026

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