15 February 2017 (updated 21 August 2019)
The targeted review of internal models, or TRIM, is a project to assess whether the internal models currently used by banks comply with regulatory requirements, and whether their results are reliable and comparable. Banks can use internal models to determine their Pillar 1 own funds requirements, i.e. the minimum amount of capital they must hold by law.
One major objective of TRIM is to reduce inconsistencies and unwarranted variability when banks use internal models to calculate their own funds requirements.
TRIM also seeks to ensure consistent supervisory practices. As a result, the review should help to make sure that internal models are being used appropriately and consistently. The objectives of TRIM are therefore in line with two major goals of ECB Banking Supervision: to foster a sound and resilient banking system through proactive supervision and the use of best practices and to ensure that supervisory practices are applied consistently across banks.
Under the project, the ECB is currently checking Pillar 1 approved models at all directly supervised banks that use them. However, not all approved models at all banks are being checked and there are a few other exceptions, e.g. banks undergoing a merger or those which may no longer be subject to direct supervision. This means that about 65 banks fall within the scope of TRIM.
The project covers credit, market and counterparty credit risk (operational risk has been excluded given the Basel Committee on Banking Supervision’s stance against using internal models for such risk).
In December 2015 the ECB decided that it would carry out a targeted review of internal models. TRIM on-site investigations started in 2017, following initial preparatory work in 2016 to identify the underlying methodology and tools and the models to be reviewed. Further on-site investigations took place in 2018 and are continuing in 2019. It is expected that around 200 such investigations will be completed during the whole project.
The project has two key phases:
In the aftermath of the financial crisis, there has been much debate about the use of internal models to determine own funds requirements. There are two main reasons for this:
TRIM therefore seeks to reduce unwarranted variability in the calculation of own funds requirements and to confirm the adequacy and appropriateness of internal models, thereby also enhancing the credibility of the internal models being used by banks subject to European banking supervision.
The project aims to reduce unwarranted variability in own funds requirements across banks, not to increase own funds requirements in general. Nevertheless, TRIM could lead to increases or decreases in the own funds needs of individual banks.
The ECB maintains an ongoing dialogue with participating banks. It provides them with regular updates on the overall status of the project, informs them of upcoming milestones, etc. This is done through dedicated conferences and workshops, regular project information letters, bilateral exchanges, and ECB staff participation in industry events.