On September 11, ISDA responded jointly with the other associations (Institute of International Finance (IIF), International Banking Federation (IBFed) and Global Financial Markets Association (GFMA)) to the Basel Committee on Banking Supervision (BCBS) consultation on interest rate risk in the banking book (IRRBB). The response reiterates these goals can be pursued within a Pillar 2 and Pillar 3 frameworks. Given the nature of IRRBB, the industry does not believe that a Pillar 1 approach is appropriate.