ISDA and Association for Financial Markets in Europe (AFME) has published a response on behalf of the Industry to the EBA's second consultation on the draft RTS for credit valuation adjustment (CVA) risk. The response states that the Industry believes that the proposals are overly prescriptive and do not reflect the diversity of industry practices and methods regarding CVA that are currently successfully in use in firms. The result is that many firms will have to introduce new processes, at a significant cost, with the sole purpose of dealing with regulatory CVA.