The International Swaps and Derivatives Association, together with the Institute of International Finance and the Securities Industry and Financial Markets Association, submitted a joint comment letter to the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on the proposed Basel III endgame capital rule for Category I and II banking organizations and firms with significant trading activity. The letter focuses on the trading book and counterparty credit elements of the proposal and argues for a final framework that is more risk sensitive and better aligned with market intermediation, hedging, financing and liquidity activities. The recommendations cover the Fundamental Review of the Trading Book, credit valuation adjustment risk and counterparty credit risk, including securities financing transactions, derivatives and the standardized approach for counterparty credit risk. They are grouped around three themes: enhancing risk sensitivity, improving consistency across capital rules and reducing unnecessary operational burdens. The associations also recommend that any final rule take effect no earlier than January 1, 2028.
ISDA2026-06-18
International Swaps and Derivatives Association joins IIF and SIFMA in urging changes to US Basel III endgame trading and counterparty capital rules
The International Swaps and Derivatives Association, with IIF and SIFMA, filed a joint comment letter on the US Basel III endgame capital proposal for large banking organizations and firms with significant trading activity. The letter targets the trading book, credit valuation adjustment risk and counterparty credit risk rules, and calls for greater risk sensitivity, more consistency across the capital framework and fewer operational burdens. It also recommends an effective date no earlier than January 1, 2028.