In its detailed IRB guidelines released in December 2011, the Bank had laid stress on the data part for most of the parameters that go into the calculation metrics, be it sovereign exposure, bank exposure, mapping to external data for PD estimation etc. 21.
These problems included insolvency, illiquidity (by which I mean the loss of access to funding even if the nonbank was solvent), and a general loss of confidence, in which counterparties of all kinds became reluctant to deal with some nonbanks.