UK Finance has responded to the PRA's consultation on Approach to Overseas IRB models (CP 16/20).

We welcomed the proposals but highlighted the impact of growth in overseas models, particularly following UK's withdrawal from the EU, and also the conflation of this proposal with EBA IRB programme and Basel 3.1 reform.

We also recommended that threshold be set at 15% of RWAs / exposure, the scope of equivalent jurisdictions be aligned with banks? overseas regional hub capital management and that SME corporate exposures be captured in addition to retail exposures in the proposal.