ISDA, AFME Publish Position Papers on CRR III

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.

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...