ARXO-2026-0391 · Reported
Basel Framework: MAR33.15 IMCC(C_i)
IMCC(C_i) in MAR33.15 contains the ratio ES_F,C,i / ES_R,C,i, which has no value for a risk class without positions. The CRR writes the convention out (Article 325bb(3) includes a risk class only where the portfolio has a modellable risk factor in it); the Basel text does not.
Consequence
Position: Bank with IMA desks in rates, equity, FX, credit only; no commodity positions. Commodity class: ES_R,S,i = 0, ES_F,C,i = 0, ES_R,C,i = 0. Reading a: IMCC(C_commodity) = 0 x 0/0 undefined, IMCC cannot be computed Reading b: class skipped / contributes 0, IMCC = rho*IMCC(C) + (1-rho)*sum over 4 classes Difference: undefined vs defined capital number; also applies when ES_R,C,i is 0 while ES_F,C,i > 0 (factors not in reduced set): ratio infinite
Proposed correction
Clarify or correct the cited passage so that the rule and its references give one result for the stated case.
- Issued by
- Basel Committee on Banking Supervision
- Act
- Basel Framework MAR33 (in force 2023-01-01, published 2020-06-05)
- Place
- MAR33.15 IMCC(C_i)
- Record
- Discrepancy
- Class
- Text of the act
- Where it arose
- The text of the act
- Arxo's conclusion
- Confirmed
- Official text
- Unchanged at last check
- Last checked
- 2026-10-31
Evidence
Reproduced by execution. Quotations are verbatim from the official material; translations are ours and marked.
ES_{R,S} is then scaled up by the ratio of (i) the current ES using the full set of risk factors to (ii) the current ES measure using the reduced set of factors.
How to check it without Arxo's tools
- Open Basel Framework MAR33 (in force 2023-01-01, published 2020-06-05) and find MAR33.15 IMCC(C_i). Compare the text with the quotation above. A copy is kept in this register: f33a3dc87d0a2684-MAR33@2023-01-01~2020-06-05.txt (SHA-256
f33a3dc87d0a26846946b21e43938925ea5c15da64019e71c2fbdb63e73444b8, copy of the official file). - The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.
How this finding was made
AI models read the texts, built the examples and reviewed the findings.
Responsible institutions
- Basel Committee on Banking Supervision — maintains the Basel Framework
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-31 | Basel Committee on Banking Supervision | https://mail.google.com/mail/u/0/#sent/KtbxLthRTjRNkqRtWGvxMWmXhVdckfWkGV |
Responses
No response recorded.
History
- 2026-10-31Confirmed by Arxo
- 2026-10-31Entered in the register
- 2026-10-31Reported to Basel Committee on Banking Supervision (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0391, https://arxo.io/findings/ARXO-2026-0391/ (status as of 2026-10-31). Data: ARXO-2026-0391.json.