Basel IV / CRR3 implementation from gap analysis to supervisory approval
End-to-end advisory on capital, liquidity, and governance frameworks. From technical design through supervisory engagement, we own the delivery to final approval.
Core Regulatory Programmes
The CRR3/Basel IV landscape is complex. Implementation requires simultaneous execution across capital, liquidity, credit risk, market risk, and governance frameworks. We manage this complexity with precision.
SA-CR Migration
Standardised Approach to Credit Risk implementation: modelling migration paths, client segmentation, exposure validation, and supervisory alignment. Parallel-run management for seamless transition.
- Client classification framework design
- Risk weight calculation validation
- Data quality remediation
- ECB supervisory approval engagement
FRTB / Market Risk
Fundamental Review of the Trading Book: sensitivity-based approach, risk factor definitions, model validation, desk-level RWA reporting. Full compliance with BCBS 457.
- Risk factor modelling
- Desk segmentation & P&L attribution
- Model governance & backtesting
- Regulatory reporting infrastructure
Output Floor & CVA
Basel IV Output Floor implementation ensuring RWA floor at 72.5% of SA. CVA risk charge optimisation. Counterparty risk framework redesign for competitive advantage.
- Output Floor RWA calculation
- CVA charge modelling
- Netting agreement review
- Hedging strategy optimisation
ICAAP / ILAAP
Internal Capital and Liquidity Adequacy Assessments under ECB Guidelines. Reverse stress testing, scenario design, concentration risk analysis, and supervisory documentation.
- Risk universe definition
- Scenario design & calibration
- Capital requirement quantification
- ECB submission management
Model Risk Governance
BCBS 239 compliance: validation framework, model inventory, governance procedures, IT infrastructure. Support for IRB models, FRTB, CVA, and risk reporting models.
- Model inventory & taxonomy
- Validation framework design
- Control environment establishment
- Ongoing monitoring setup
Pillar 3 Disclosure
Comprehensive regulatory reporting: template completion, data extraction, reconciliation, narrative disclosure. Full alignment with CRR3 schedules and ECB templates.
- Data mapping & reconciliation
- Template population
- Narrative content development
- Supervisory alignment
Key Regulatory Tags
Eight pillars. One disciplined path from CRR3 gap to supervisory approval.
Most regulatory programmes drift between legal interpretation, IT delivery, and model validation. Ezelman imposes a single operating grammar — DELIVERY™ — that keeps CRO, CFO, Supervisory Liaison, and Programme Director aligned across 18-to-36 months.
Used on every Ezelman CRR3 and Basel IV mandate since 2022. Memorise it. Quote it. Defend it.
DIAGNOSE
Gap analysis CRR3 vs. current rulebook. Quantify RWA/CET1 impact by portfolio.
ENGAGE
Open supervisory dialogue early. Anchor interpretations before the JST locks a position.
LEAD
Board-level sponsorship. Translate regulatory mandate into strategic capital narrative.
IMPLEMENT
Taxonomy, methodology, data pipelines, calculation engines — built once, built right.
VALIDATE
Independent model validation + dual-run reconciliation. Kill surprises before supervisors find them.
EMBED
Embed within risk, finance, and IT teams. Knowledge transfer while we deliver.
REPORT
COREP / FINREP / Pillar 3 under the new taxonomy. Narrative, not just numbers.
YIELD
RWA optimisation and capital release post-transition. The reason the Board funded this.
Our Approach
Regulatory implementation is not purely technical. It requires translation between business, risk, finance, and supervisory languages. We orchestrate this alignment.
Design Phase
We begin with strategic design workshops with your board, CRO, and CFO. What does effective capital management look like for your franchise? How do regulatory requirements intersect with competitive strategy?
- Gap analysis against CRR3/Basel IV
- Regulatory impact quantification
- Business case & competitive positioning
- High-level implementation roadmap
Build Phase
Technical implementation of frameworks, models, and reporting systems. We embed within your teams, enabling knowledge transfer whilst maintaining delivery momentum.
- Framework & taxonomy design
- Data infrastructure build
- Model development & validation
- System integration & testing
Supervisory Engagement
We lead dialogue with ECB, NCAs, and other regulators. Proactive clarification of technical interpretations, early signalling of implementation approach, management of feedback cycles.
- Supervisory strategy & messaging
- Technical documentation preparation
- Q&A management & escalation
- Approval navigation
Transition & Optimisation
Managed transition to steady-state operations. Optimisation of RWA, capital, and liquidity metrics within regulatory constraints. Continuous monitoring and supervisory adaptation.
- Parallel-run management
- System cutover & validation
- RWA & capital optimisation
- Ongoing regulatory evolution
Why Regulatory Programmes at Ezelman
Regulatory implementation requires equal parts technical mastery and supervisory savvy. Our team brings both.
Deep CRR3/Basel IV Expertise
Team members authored Basel IV standards at BIS. We don't interpret regulation — we understand the original intent of the drafters. This translates into faster, cleaner implementations.
ECB & NCA Relationships
Direct relationships with ECB Banking Supervision, NCAs across Europe, and major investment banks' regulatory teams. We know how supervisors think and what matters to them.
Proven Track Record
Multi-year engagements with six global systemically important banks on capital and liquidity transformation. From gap analysis to final approval. Successful CRR3 implementations in production.
Execution Excellence
We don't leave the delivery to junior staff. Every major milestone is signed off by a founding team member. You get accountability and experience on every deliverable.