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Basel Endgame Re-Proposal Sows Optimism for U.S. SRT

March 27, 2026

Cadwalader partners Jed Miller, Daniel Meade and Christopher Horn were recently featured in 9fin’s analysis of the Basel Endgame re-proposal and its implications for the U.S. SRT market.

Jed explained that the re-proposal is going to be good for the SRT market, as it “creates more certainty and creates more validation of the product,” noting that “many of the banks that do these trades are not doing them because they're necessarily capital-constrained, but there is a cost of regulatory capital that may be greater than the cost of doing SRT.”

Chris broke down how “the philosophy of the Basel Committee standards is to permit the use of internal models because they're risk sensitive, but subject them to an output floor” — a model the Collins Amendment “effectively did away with” in the US. He said that “banks have their individual use cases for SRT. It’s not always about improving capital ratios,” as “banks will still want to be efficient in how they allocate their regulatory capital, even if they’re choosing to hold capital above the minimum requirements.”

Dan added, “Notwithstanding that we're past the Super Bowl, I don't think we're going to see Super Bowl ads from banking advocacy trade (organizations).”

Read the full 9fin article here.

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