The European Central Bank (ECB) have published an opinion on the proposal for a Directive amending the Capital Requirements Directive in respect of capital requirements for the trading book, re-securitisations, and the supervisory review of remuneration policies (CRD 3). The opinion sets out a number of general observations outlining the ECB's concerns about certain CRD 3 provisions. It also includes some specific drafting proposals to amend CRD 3.

The text of CRD 3 approved by the European Parliament in July 2010 states that the provisions relating to remuneration will take effect in January 2011, but the provisions relating to capital requirements (that is, the provisions relating to re-securitisations, disclosure of securitisation risks and trading book) will take effect no later than 31 December 2011.

The new CRD 3 rules on bonus provisions will take effect in January 2011 and the new rules on capital requirements will come into force no later than 31 December 2011.