On October 13, 2023, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint letter responding to the European Banking Authority (EBA) on its report on the standardized approach for counterparty credit risk (SA-CCR).

The letter states the associations’ concerns about the significant impact on capital requirements from the current SA-CCR calibration and provides feedback on some of the points raised by the EBA in its report on May 30, 2023. In particular, the letter identifies the impact of a reduced alpha factor for the output floor calculation and how the assessment conducted by the EBA unduly impacts banks that have permission to use the internal model method. Due to the issues in the methodology chosen by the EBA, the letter expresses concerns about the conclusions of the report and urges policymakers to reconsider the SA-CCR calibration.