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
Response to EC Call for Evidence on Tax Omnibus
On March 30, ISDA, the International Securities Lending Association and the Association for Financial Markets in Europe responded to the European Commission’s (EC) call for evidence on the tax omnibus. The associations argue that inconsistent interpretation of “beneficial ownership” among...
Managing Risk for Australian Superannuation Funds
Assets managed by the Australian superannuation sector reached A$4.5 trillion in December 2025, equivalent to around 160% of Australia’s GDP. Given its size, the sector has rapidly expanded its global footprint, with the share of offshore investments growing as a...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Next Steps on a Much Improved Basel III Endgame
Publication of the revised Basel III endgame proposal earlier this month marks an important step towards completion of the global capital reforms, giving banks much-needed clarity on the likely calibration of the rules in the US. The new proposal is...
