Three-year programme for a major European G-SIB: full programme ownership of SA-CR, FRTB, Output Floor, and CVA across all risk classes, geographies, and legal entities.
The client faced a complex 36-month roadmap to full CRR3 compliance across four major regulatory workstreams — SA-CR, FRTB, Output Floor, and CVA Risk Charge. With operations spanning 15 jurisdictions and multiple business units (Investment Banking, Asset Management, Lending, Trading), coordination, knowledge transfer, and governance risk were significant. The bank's internal teams had limited CRR3 implementation experience, and supervisory expectations were rapidly evolving. A delay in any workstream risked supervisory escalation and reputational impact.
We took full programme ownership, establishing a steering committee chaired by a senior practitioner with 20+ years of G-SIB regulatory experience. We deployed the Ezelman DELIVERY™ framework — the eight-pillar operating grammar that kept CRO, CFO, Supervisory Liaison, and Programme Director in lockstep over 36 months.
CRR3 gap analysis across 15 jurisdictions; quantified RWA impact by portfolio in 8 weeks.
JST alignment sessions in month 2 anchored SA-CR interpretations before external specs.
Board-level sponsorship; CRR3 reframed as capital-optimisation narrative, not cost.
Taxonomy, calculation engines, data pipelines for SA-CR, FRTB, Output Floor, CVA.
Independent validation and 60-day dual-run across 12 legal entities; 2% variance.
Client teams led workstream delivery by month 24; advisory dependency phased out.
COREP / FINREP / Pillar 3 under new taxonomy with narrative supporting every delta.
Post go-live RWA optimisation released 65 bps CET1 — funded the programme 3x over.
Beneath the framework, three operating principles carried the programme:
Weekly steering meetings with the CRO and CFO. Monthly supervisory-readiness reviews. Governance model embedded accountability at business unit and central risk levels. We drafted and maintained the client's CCAR/ICAAP and CRR3 compliance calendars, ensuring no regulatory deadlines were missed.
Dedicated senior advisors for each pillar (SA-CR, FRTB, Output Floor, CVA). Monthly implementation meetings, gap-closure tracking, and real-time guidance on supervisory expectations. Each workstream was delivered to "first-time supervisory acceptance" standard.
We trained the client's core teams in CRR3 interpretation, model validation, and supervisory communication. By month 24, client teams were leading workstream delivery with our oversight. This reduced long-term advisory dependency and strengthened internal capability.
Quarterly mock-inspection sessions with ECB-experienced advisors. We drafted responses to anticipated supervisory questions, stress-tested the bank's interpretations against recent ECB decisions, and ensured compliance documentation met SSM standards for rigour and clarity.
Full migration from IRB to standardised approach for material non-IRB portfolios, including CCF calibration, exposure classification, and reporting infrastructure. We modelled RWA impact across 12 legal entities, identified efficiency opportunities (leveraging existing IRB frameworks), and delivered a 60-day parallel-run protocol. Result: Smooth transition with 2% RWA variance vs. supervisory expectations.
Complete redesign of market risk capital methodology across spot, derivatives, and securitisation portfolios. This involved implementing the Sensitivities-based Approach (SBA) and Incremental Risk Charge (IRC) for linear and non-linear instruments. We built governance frameworks for desk-level risk attribution, designed the model validation protocol, and trained risk teams on FRTB logic. Delivered to ECB inspection standards.
Quarterly floor calculations across the group. We established the architectural framework for IRB vs. standardised RWA reconciliation, documented IRB model assumptions (for supervisory transparency), and designed exception-handling protocols. Client's Output Floor tracking became a monthly executive KPI, with escalation triggers built into governance.
Implementation of the CRR3 CVA framework (replacing Basel III CVA) for derivative portfolios. This required detailed counterparty-level exposure modelling, hedging effectiveness assessment, and stress testing. We delivered the model, validation framework, and supervisory documentation within 18 months.
36-month implementation plan, risk register, and supervisory calendar. Quarterly updates aligned with EBA/ECB guidance releases.
RACI model, steering committee charter, workstream accountability matrix, and escalation protocols.
Complete technical documentation for SA-CR, FRTB, Output Floor, and CVA models — pre-packaged for ECB inspection.
Role-based training for CRO, CFO, risk teams, and business units. Monthly "Supervisor's Perspective" briefings for the Executive Risk Committee.
20+ regulatory correspondence packages (response to ECB data requests, interpretation letters, and interim compliance reporting).
60-day parallel-run protocol for SA-CR. Model validation reports for FRTB and CVA. Testing protocols for Output Floor mechanics.
The client achieved full CRR3 compliance within the 36-month timeline, delivering: