BBA has responded to EBA’s consultation on capital requirements for CCPs. Its main comment is that, although it makes sense to take the CRD requirements as a starting point, CCPs have a different purpose from regulated entities. CCPs aim to minimise risk, whereas regulated entities aim to balance risk and reward. Because of this difference, CCP capital structures will be different and so not all requirements relevant to regulated entities should apply to CCPs. It also notes further issues EBA should address, such as large exposures. (Source: BBA Responds on CCP Capital)