On September 26, 2022, ISDA and the Association for Financial Markets in Europe published a whitepaper on the prudential boundary between the banking and trading books in Europe and how that relates to instruments with embedded derivatives.
New requirements under the EU’s third Capital Requirements Regulation (CRR 3) that are related to the prudential allocation of risks between the banking book and trading book, and internal risk transfers between them, could cause unintended consequences for the capital treatment of instruments with embedded derivatives. This could lead to a disproportionately high risk-weighted assets calculation, which could render certain activities uneconomic.
This paper provides an overview of the different types of instruments with embedded derivatives, as well as the accounting and current prudential treatment of these products. The paper also provides an analysis of the various business and booking models for structured issuances to ensure a correct prudential book allocation. The industry believes that policymakers should consider the recommendations in the paper and amend the European Commission’s proposed CRR 3 accordingly.
Documents (1) for Treatment of Instruments with Embedded Derivatives
Latest
ISDA ALF: Katherine Tew Darras Opening Remarks
ISDA Annual Legal Forum London, February 11, 2026 Opening Remarks Katherine Tew Darras ISDA General Counsel Good morning and welcome to ISDA’s Annual Legal Forum. Thank you for joining us today and thanks to our platinum sponsors – Cleary...
Maintaining Focus on Basel III Endgame Recalibration
In its original form, the US Basel III endgame proposal would have resulted in disproportionate increases in capital for trading book activities, forcing banks to make difficult choices about their participation in certain businesses. After two-and-a-half years, a revised proposal...
IRRBB Management in EMDEs
Interest rate risk in the banking book (IRRBB) has become a growing priority for banks and regulators in emerging market and developing economies (EMDEs). As many of these countries face monetary tightening cycles and ongoing macroeconomic volatility, bank balance sheets...
Response to CPMI-IOSCO on Consultation
On February 5, ISDA and FIA responded to the Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) consultation on the management of general business risks and general business losses by financial market infrastructures (FMIs)....
