BBA, ISDA and the AFME have responded to the Commission on its plans for CRD IV. They welcome the initiative to enhance the CRD but stress:

  • the focus for the year should be on agreeing the structure of the framework. Detail and calibration will take longer;
  • industry would welcome a further round of consultation after quantitative impact studies planned by the Basel Committee and the Commission take place;
  • the overarching key issues are calibration and impact assessment, timing and sequencing, and consistent implementation; and
  • other significant issues are liquidity, capital and deductions, leverage ratio, counterparty credit risk and countercyclical measures.

(Source: Response to the European Commission on CRD IV: Commission Services Staff Working Document: Possible further changes to the Capital Requirements Directive – February 2010)