ARXO-2026-0399 · Reported
Basel Framework: RBC25.9 FAQ3
RBC25.9 FAQ3 says an FX option hedging a banking book position is covered by RBC25.9(6), which only lists options on credit or equity risk from the bank's own issued instruments.
Consequence
Position: Bought EUR/USD option, notional 50, hedging FX risk of a banking-book SME loan. Reading a: FAQ3: presumptive trading book unless supervisor approves; RBC25.8(8) overridden. Reading b: RBC25.9(6) does not apply; RBC25.8(8) applies, banking book. Difference: Market risk capital on notional 50 vs none.
Proposed correction
Clarify or correct the cited passage so that the rule and its references give one result for the stated case.
- Issued by
- Basel Committee on Banking Supervision
- Act
- Basel Framework RBC25 (in force 2023-01-01, published 2020-03-27)
- Place
- RBC25.9 FAQ3
- Record
- Discrepancy
- Class
- Text of the act
- Where it arose
- The text of the act
- Arxo's conclusion
- Confirmed
- Official text
- Unchanged at last check
- Last checked
- 2026-10-31
Evidence
Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.
An option that manages FX risk in the banking book is covered by the presumptive list of trading book instruments included in RBC25.9(6).options including embedded derivatives[fn5] from instruments that the institution issued out of its own banking book and that relate to credit or equity risk.
How to check it without Arxo's tools
- Open Basel Framework RBC25 (in force 2023-01-01, published 2020-03-27) and find RBC25.9 FAQ3. Compare the text with the quotation above. A copy is kept in this register: b168d28f63040730-RBC25@2023-01-01~2020-03-27.txt (SHA-256
b168d28f630407304f9593368dc687fbbe5358dd9dce0d6f2bdc77481b398452, copy of the official file). - The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.
How this finding was made
AI models read the texts, built the examples and reviewed the findings.
Responsible institutions
- Basel Committee on Banking Supervision — maintains the Basel Framework
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-31 | Basel Committee on Banking Supervision | https://mail.google.com/mail/u/0/#sent/KtbxLthRTjRNkqRtWGvxMWmXhVdckfWkGV |
Responses
No response recorded.
History
- 2026-10-31Confirmed by Arxo
- 2026-10-31Entered in the register
- 2026-10-31Reported to Basel Committee on Banking Supervision (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0399, https://arxo.io/findings/ARXO-2026-0399/ (status as of 2026-10-31). Data: ARXO-2026-0399.json.