ISDA and AFME wrote to the European Commission (“EC”) regarding the EC compromise draft on capital requirements for bank exposures to central counterparties (“CCPs”) in the Capital Requirements Regulation (“Draft CRR Text”) observing a number of differences between the Draft CRR Text and the Basel international standards set out in the interim framework for determining capital requirements for bank exposures to CCPs, viz. BCBS 227 of July 2012.