ISDA and AFME have written to the Commission pointing out deviations of the draft CRR text from Basel 3. These are the requirement to hold additional regulatory capital for “contractually committed contributions” to Central Counterparties' (CCP) default funds and the requirement for banks to hold capital for trade exposures with a CCP where the bank purely acts as financial intermediary. The associations say that these requirements imply a double counting of risk. (Source: ISDA and AFME Letter to Commission on Capital Requirements for Exposure to CCPs)