On October 11, ISDA & The Institute of International Finance (IIF) responded to the Basel Committee on Banking Supervision (BCBS) Discussion Paper ‘The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability’. The response focuses on the ramifications of changes to the current framework for member institutions and the broader financial system, and considers possibilities going forward that would capture perceived deficiencies in the risk based framework whilst not jeopardizing the objectives of risk sensitivity and transparency.