On February 12, 2015, ISDA responded jointly with the Association for Financial Markets in Europe (AFME) to the European Banking Authority (EBA) consultation on guidelines on the treatment of credit valuation adjustment (CVA) risk under the supervisory review and evaluation process. The ISDA/AFME response challenges the need for the proposed guidelines, suggesting that the right place to make changes to the CVA framework is at the Basel level. It also highlights the duplicative nature of the proposals with existing SREP guidance and the resulting overriding of the EU CVA exemptions.