ISDA and AFME (the Association for Financial Markets in Europe) have written to the Commission highlighting their disagreement with differences between the draft CRR and the Basel Committee’s interim framework. They consider the risk weight of 1250% to a CCP’s pre-funded default fund to be excessive. Additionally, the requirement for capitalisation of the risk arising from committed contributions to a CCP default fund would amount to double counting. (Source: ISDA/AFME Letter to EC re. Capital Requirements Regulation)