US banks now have only a few months to decide which desks to put through IMA approval and the revised proposal changes the math. In March 2026, the Federal Reserve, OCC, and FDIC issued a broadly capital-neutral framework that replaces the 2023 proposal, treats the SA charge as a cap on IMA capital, and softens the model-eligibility tests. Consultation closes June 18, 2026; final rules are expected in Q4 2026, with implementation targeted for 2027.
The Fed proposes that NMRFs can be modelled on far fewer observations (24) than previously (100). It also proposes Type A (bringing a lighter capital charge) and Type B (the original SES treatment). They also propose a simplification of the P&L Attribution Test (PLAT), dropping the Spearman test and making the KS test non-binding for the next three years. However, the VaR back testing is still an important part of IMA and remains unchanged.
Atoti FRTB is already in production at leading banks across the US, Europe, and Asia. It was built for exactly this situation: regulatory change requiring swift impact assessment, continuous optimization, and reliable regulatory reporting.
Assessing Impact Quickly
When major regulatory proposals land, the banks that move fastest are the ones that can model the capital impact on their specific book within days. Atoti runs full SA and IMA calculations across the live trading book, so risk teams can see what revised rules mean for their desks without waiting on a separate impact study.
Atoti Intelligence’s Auto-Explain capability identifies the drivers of capital charge movements at desk, instrument and trade level, delivering natural-language explanations of moves that would otherwise require manual desk-by-desk attribution.
The SA/IMA Optimization
Every bank must run the Standardized Approach. The decision is whether to run IMA approval for some or all trading desks, and the new proposal makes that decision more significant.
Treating the SA charge as a cap on IMA capital requirements changes the cost-benefit analysis for desks with well-diversified books. For some, IMA becomes significantly more attractive than it was under the 2023 framework. For others, the SA alone will be sufficient. Atoti FRTB can run both approaches simultaneously, even on the same desks. Risk managers can evaluate IMA candidacy by desk, model the impact of P&L Attribution Test outcomes, and stress-test capital charges across scenarios, all within a single platform.
One Platform Across Jurisdictions
The US proposal is one piece of a fragmented global picture. The EU has deferred FRTB to January 2027 and is consulting on a temporary multiplier to offset the capital impact on trading activities for up to three years. The UK has finalized its Basel 3.1 package for January 2027, with the FRTB Internal Model Approach deferred to January 2028.
For internationally active banks, this means managing different parameter sets, different timelines, and different regulatory expectations in each region. Atoti FRTB handles BCBS, CRR3, and US-specific rules within a single platform. There is no need for separate jurisdiction-specific systems, and no risk of inconsistent calculations across regions.
Regulatory Submission with Confidence
Getting from calculation to regulatory submission is where many institutions lose time. The sign-off process is manual, labor-intensive, and subject to tight deadlines. Atoti FRTB’s agentic workflows automate data quality checks, flag exceptions, and guide the approval chain from calculation through to submission, with a full audit trail at every step. Risk managers spend their time reviewing exceptions, not chasing data.
Banks using Atoti FRTB can assess the impact of the new parameters now, make informed SA/IMA decisions ahead of finalization, and go into production on infrastructure already running FRTB calculations at peer institutions.
To understand how Atoti FRTB can help your institution assess the capital impact of the new proposal and prepare for 2027 implementation, contact us.
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