Summary of stakeholder feedback and OSFI’s responses for the public consultation on Guideline B-12 – Interest Rate Risk Management
| Topic | Stakeholder feedback | Response |
|---|---|---|
| Dynamic and constant views of the balance sheet | Clarify whether the proposed guidance on how institutions should consider different types of balance sheet scenarios against earnings measures applies to Category 2 small and medium-sized deposit-taking institutions (SMSBs). | The guidance applies to all federally regulated deposit-taking institutions, including Category 2 SMSBs. However, as paragraph 34 (c) states, institutions may consider the dynamic balance sheet view and its impact on earning measures, depending on the institution’s nature, size, business, complexity, and risk profile. A constant balance sheet approach represents the minimum expectation for assessing earnings sensitivity. Institutions may adopt a dynamic balance sheet view when it aligns with their business model or risk profile. For example, significant projected growth or changes in product mix may materially affect earnings sensitivity. The final Guideline B-12 does not include any revisions related to this feedback. |