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Article June 26, 2026

Higher for Longer Demands a New IRRBB Playbook

Higher for Longer Demands a New IRRBB Playbook

Center for Financial Professionals

Banks can no longer manage interest rate risk through static assumptions and regulatory compliance alone. As rate volatility, digital banking, and faster-moving depositor behavior reshape the landscape, institutions are being pushed toward more dynamic IR

Banks must stop treating interest rate risk as a standalone modeling exercise and instead embed it within a broader balance sheet management framework if they are to navigate a higher-for-longer rate environment successfully, senior industry leaders and supervisors argued during a recent discussion on interest rate risk in the banking book.

The debate highlighted how sustained rate volatility, evolving depositor behavior, digital banking, and diverging regulatory expectations are forcing institutions to rethink long-established assumptions about interest rate risk management.

Speaking at CeFPro's recent Risk Evolve conference in London, a senior supervisor from a major European regulatory authority said interest rate risk remains a unique challenge because it sits largely within a Pillar 2 framework, creating significant scope for supervisory judgment and model variation.

"We have strengthened our methodology," said the supervisory executive, describing increased focus on behavioral modeling, stress testing, governance frameworks, and hedging strategies.

He noted that recent reviews have paid particular attention to non-maturity deposit modeling and the lessons learned from recent banking sector failures.

According to the regulator, behavioral assumptions remain among the most important and challenging aspects of interest rate risk management.

The supervisor explained that institutions are increasingly being assessed on how effectively they model customer behavior, deposit stability, and responses to changing interest rate environments. Credit spread risk in the banking book has also emerged as an area receiving increased supervisory attention.

A prudential risk leader from a major UK banking group argued that banks need a much broader perspective than interest rate scenarios alone.

"A framework for interest rate modelling and IRRBB modelling cannot be done in isolation just through interest rates," he said.

Instead, he advocated what he described as a conscious balance sheet management framework in which balance sheet behavior is modeled through customer, market, and macroeconomic drivers simultaneously.

The executive suggested that understanding customer behavior is increasingly central to managing interest rate risk, particularly as institutions attempt to distinguish between stable and volatile deposits and anticipate future balance sheet movements.

A treasury risk director from a major global custody bank highlighted another growing challenge: regulatory divergence.

From an industry perspective, he argued that differing approaches between European, UK, and US regulators are creating significant complexity for internationally active banks.

"The divergence across jurisdictions when you're managing internationally" has become one of the industry's biggest operational challenges, he said.

The executive pointed to differences in supervisory shocks, earnings metrics, and customer behavior assumptions, all of which can result in different interpretations of risk across jurisdictions.

As a consequence, senior management teams often face multiple versions of the same risk metric, each calculated using slightly different assumptions and regulatory requirements.

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