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 Guidance – Delayed CPI-U Due to Government Shutdown
On November 7, 2025, ISDA published guidance addressing the potential delay in the release of the U.S. Consumer Price Index for All Urban Consumers (CPI-U) resulting from the current U.S. government shutdown. The guidance provides clarification on how such delays...
SPS Matrix – SPS Naming Convention
This document sets out the naming convention for how the Settlement Price Sources (“SPSs”), as defined in the ISDA Digital Asset Derivatives Settlement Price Matrix (the “SPS Matrix”), should be named to increase consistency and understandability. ISDA formalized the SPS...
A Global Blueprint for Market Risk Reform
The global financial crisis of 2007-2009 exposed fundamental weaknesses in how banks measured and managed risk, and the repercussions were felt by economies all over the world. In response, policymakers sought to rebuild trust and resilience in the global financial...
SwapsInfo Q3 2025 and Year-to-September 30, 2025
Trading activity in interest rate derivatives (IRD) and credit derivatives increased in the third quarter of 2025 compared with the same period in 2024, reflecting shifting monetary policy expectations and broader market conditions. IRD traded notional rose by more than...