On August 28, ISDA and the Institute of International Finance (IIF) submitted a joint response to the Basel Committee on Banking Supervision’s (BCBS) consultation on guidelines for counterparty credit risk (CCR) management. The new guidelines represent an update to the Sound Practices for Banks’ Interactions with Highly Leveraged Institutions, published in January 1999, to incorporate recent lessons and best practices. In the response, the associations stress the guidelines should be risk-based and proportional, considering a diverse universe of counterparties and financial markets across the world. The associations believe a common understanding and coordination between central banks, supervisors and banks can enhance the effectiveness of CCR practices. The response also highlights the importance of having flexible disclosure requirements based on the risk profile of different client segments, acknowledging that banks may encounter challenges in obtaining certain information from their counterparties. Finally, the response notes that proportionality is central to efficient regulation, and impractical measures and those with high implementation costs relative to their benefits should be removed to prevent an overly burdensome framework that could undermine the guidelines’ objectives