On June 21, ISDA and GFMA provided comments to the BCBS in response to their consultation document Recognizing Cost of Credit Protection Purchased (published 22 March 2013). Industry were concerned that the proposed rule would have a disproportionate effect on a wide range of banks’ financing activities (both in corporate and investment banking), wherever banks seek to hedge borrower credit risk or associated counterparty risk. In addition the groups voiced concerns about synthetic securitization transactions, non-securitization transactions, the potential impact of changes to the accounting standards affecting loan loss reserves and additional questions posed in the BCBS Consultation Document.