The International Swaps and Derivatives Association (ISDA), the London Investment Banking Association (LIBA), the British Bankers’ Association (BBA), and the European Securitisation Forum (ESF) welcome the opportunity to comment on the second round of consultation on the Validation and Assessment of Advanced Measurement (AMA) and Internal Ratings Based (IRB) Approaches (“CP10R”) published towards the end of January 2006. Our combined membership represents a diverse group of internationally active financial institutions, operating across the broad spectrum of European and international capital markets. . .