Joint Trade Association letter (BBA, LIBA, ISDA, CMSA-Europe, IACPM, EBF, SIFMA and the ESF) with regard to the European Commission Service’s alternative proposal to amend the Capital Requirements Directive (CRD) to address incentives in the “originate-to-distribute” (OTD) model. Submitted to Commissioner McCreevy (European Commission), cc-ing Member States, EU Commissioners, and Commission Services

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