Together with Bank Policy Institute (BPI), the Swiss Finance Council, UK Finance, the UK Association of Foreign Banks (AFB), the Bankers Association for Finance and Trade (BAFT), and the Japanese Bankers Association (JBA), the LMA has published a position paper on EU Member States’ implementation of the branch requirement under CRDVI. This paper is intended to:

• highlight the approach that we believe best aligns national transposition with the policy intent behind CRD VI; and
• identify areas where certain transposition proposals or interpretations to date appear to have inadvertently diverged from the Level 1 text or policy intent.

On 8 August 2025, the European Banking Authority published a Q&A response (prepared by the European Commission) on the use of conditional sale agreements as a means for an entity to qualify as an originator.

We are aware of the widespread use of conditional sale agreements in CLO structures and the impact that this response has had in the CLO market, particularly for those deals that have closed or priced but not yet closed.  We have contacted the European Commission, the European Banking Authority and other supervisory authorities to seek further clarification on the application of the response to these transactions.

On 9 July 2025, the FSB published its Final Report on leverage in Non-Bank Financial Intermediation (NBFI).

The LMA will continue to work with authorities on the next phase of work under the FSB to continue to push for a flexible approach to regulation due to the vast and varied nature of the NBFI market. Click Read More to access a copy of the LMA’s response to FSB earlier this year.