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Recent crises in the financial industry have shown weaknesses in the modeling of Risk-Weighted Assets (RWA). Relatively minor model changes may lead to substantial changes in the RWA numbers. Similar problems are encountered in the VaR-aggregation of risks. In this article we highlight some of the underlying issues, both methodologically as well as through examples. In particular we frame this discussion in the context of two recent regulatory documents we refer to as Basel 3.5.doi:10.3390/risks2010025 fatcat:b26uknqysjh4bemnmzxjtgfxdm