ISDA and the Association for Financial Markets in Europe (AFME) have published joint position papers on the third Capital Requirements Regulation and the sixth Capital Requirements Directive (CRR III / CRD VI).

The banking proposal was published by the European Commission on October 27 at an important time as policy-makers deal with the fallout from the COVID-19 pandemic and the need to ensure a strong and sustained economic recovery. This makes it even more important that the package is carefully designed and calibrated so that it does not constrain banks’ ability to support the economy.

CRR III also needs to be considered in the context of the EU’s urgent priorities to complete the Banking Union, reduce fragmentation of financial markets and develop and deepen Europe’s capital markets through the establishment of an effective Capital Markets Union.

In this publication, ISDA and AFME present recommendations to ensure CRR III is faithful to the overarching objectives of Basel III but also reflects these priorities.