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… their application. The key revisions are summarized below. Credit risk requirements We are clarifying the expectations … the treatment of Combined Loan Products (CLPs) under the credit risk Standardized Approach (SA) and Internal … revision will better align the capital treatment under the credit risk SA and IRB approach with institutions' internal …

… lenders’ analysis on predictors of default and agree that credit score and other factors can be better predictors than … said, high household indebtedness is still relevant to credit risk, the safety and soundness of FRFIs, and the … borrowers with compensating attributes (e.g., higher credit scores). OSFI should adopt consistent formulas and …

… (G-SIBs) and Canadian D-SIBs; and recognizing eligible credit risk mitigation techniques for measuring exposure, … exposure, etc.). The measure for indirect exposure via credit risk mitigation techniques, such as collateral … value on the basis that such transactions have inherent credit risk mitigating conditions. OSFI does not believe that …

… higher from a recognized, widely followed North American credit rating agency; commercial paper rated A-1 or R-1 or … equivalent by a recognized, widely followed North American credit rating agency; acceptances of banks and trust and loan … equivalent by a recognized, widely followed North American credit rating agency; and high quality common and preferred …

… and qualitative data used to assess and manage credit risk should be adequately maintained. Institutions … will include, but not be limited to, borrower information, credit transaction details, portfolio risk characteristics, … data processing infrastructure for life-cycle tracking of credit data including, but not limited to, relevant history …

… Federally Regulated Trust and Loan Companies, Co-operative Credit and Co-operative Retail Associations, Federally … should consider what valuation adjustments are “relevant”. Credit Risk – P.8 It is unclear what “exceptions to … the approval requirement is for approval of non-standard credit-related ISDA terms, as ISDA master agreements often …

… in respect of the IRB implementation and approval; The credit risk approach to be adopted by the parent institution … Basel framework Footnote 7 ; Any differences in Pillar I credit risk approaches between the parent institution and the … institution to indicate the amount and percentage of gross credit assets and the IRB credit risk-weighted assets covered …

… risk management expectations for home equity lines of credit (HELOCs). The Guideline also treats reverse mortgages and any non-amortizing (revolving) credit product secured by residential property as HELOCs. The … is foundational. Guideline B-20 clarifies that additional credit beyond this LTV limit can be extended to a borrower; …

… OSFI supervision on an on-going basis. Use of Letters of Credit Some respondents argued that the use of letters of credit as a risk mitigation technique should not be restricted. Letters of credit are deemed to be legally enforceable instruments. …