商业银行市场风险管理新规落地：厘清职责边界，推进全流程精细化管控

Core Viewpoint - The newly issued "Market Risk Management Measures" by the National Financial Regulatory Administration represents a significant update to market risk management requirements in China, enhancing the framework established in 2004 and addressing the evolving financial landscape [1][2]. Group 1: Regulatory Updates - The "Measures" provide clearer risk boundaries, stricter governance requirements, and a more systematic management process to help banks manage market risks during extreme market conditions [1]. - The evolution of market risk management in China has progressed through several key regulations since 2004, culminating in the 2025 "Measures" which refine the governance structure and enhance operational resilience in market risk management [2]. Group 2: Governance Responsibilities - The "Measures" clarify the responsibilities of the board of directors, supervisory board, and senior management in market risk management, establishing a clear delineation of duties across three lines of defense [2]. - Banks are required to strengthen market risk management at the group level, ensuring that all subsidiaries align with the group's risk appetite and regulatory requirements [3]. Group 3: Market Risk Management Framework - The "Measures" mandate a comprehensive and refined approach to market risk management, emphasizing six key areas: scope redefinition, governance upgrades, consolidated reporting, data and valuation, stress scenarios, and model validation [4]. - Large and medium-sized banks with established market risk management systems are encouraged to conduct gap analyses against the "Measures" to ensure compliance, while smaller banks are advised to develop lightweight organizational structures tailored to their specific risk profiles [4]. Group 4: Integration with Global Standards - Domestic regulatory bodies are actively integrating into the global capital regulatory framework, prompting banks to enhance their capital measurement frameworks and risk model systems [4]. - Banks are focusing on building robust model risk management systems that ensure effective governance, lifecycle management, and technological empowerment, creating a closed-loop information support platform for model development and business application [4].