EBF has responded to the Basel Committee's discussion paper on balancing risk sensitivity, simplicity and comparability under the current prudential regulatory framework. EBF argues that Basel 2 did not create the crisis and that models are part of the solution, not part of the problem. It points to a study by Barclays concluding that the results deriving from models include a substantial margin of conservatism to cover unexpected losses. Differences in internal models should be worked out with supervisory convergence and common guidance. (Source: EBF Responds on Balancing Prudential Regulatory Objectives)