Quantifying MoC A for a change in the definition of default which has no impact
-
We have made a change to our definition of default (required to close regulatory findings). The change is purely process-related and concerns a trigger for a default test, i.e. a trigger specification for a soft UTP criterion. Given data restrains, we could only argue qualitatively plus show based on a data sample that the change has no effect on default setting. Since we have no full historic analysis, the EGIM (ECB guide on internal models) seems to require that we quantify a MoC A for the remaining uncertainty that we might have missed cases in which the change might have an effect.
Our questions:
- Would you quantify a MoC A for the effected PD models in such a case (only sample data, but qualitative argumentation for "no effect")?
- What would be a suitable approach to quantify the MoC A in this case? We are debating a bootstrapping approach, but lack "trigger with default" cases to draw from.