【正文】
current and future developments in banks’ credit risk management systems – recognised also in the new capital adequacy regime proposed by the Basel Committee on Banking Supervision – may provide accounting standardsetters with useful elements to refine their methodologies, in particular regarding the measurement of credit risk. Doubts are also raised with regard to the application of FVA to the liability side of banks. For instance, the suggested methodology (the socalled “own credit risk”) to determine the fair value of debt instruments issued by banks entails that, if the rating of a bank deteriorates, the value of its equity will ultimately increase (since the difference in revaluation of debt instruments is accounted in the profit and loss account). This oute is counterintuitive and can be misleading for shareholders and creditors. Third, the issue of prudence. The use of FVA in the banking book would entail that potential profits and losses would be treated in the same way, by being recognised as soon as they emerge. This goes against the principle of prudence according to which losses stemming from the banking book should be recognised as soon as they are known, even if only potential, whereas profits should be recognised only if they are actually realised. Potential profits should be recognised only for marketable instruments. Therefore, there is the possibility that the application of FVA to the banking book might induce banks to adopt an imprudent behaviour. This is a crucial aspect also from the viewpoint of the banking supervisory function. III. Possible way forward In light of the critical aspects mentioned above, the ECB has a negative stance towards the possibility of applying an FVA regime to the banking book of banks. Against this background, the following developments could be considered in order to make a constructive use of the valid arguments that lie behind FVA. A first development would entail that, whereas FVA would not be recognised as an accounting standard for the banking book of banks, supervisory authorities might use it as a supplementary instrument to plement their assessment of the situation of individual credit institutions. A second development involves the adoption by banks of the socalled “dynamic provisioning”. This entails recognising that a proportion of the loan portfolio can deteriorate in the future and that this proportion can be measured ex ante on the basis of a specific statistical analysis. It would also involve the disclosure by banks of the r