Déjà vu all over again? Impact of re-proposed US Basel III regulatory capital rules on significant risk transfer (SRT) and credit risk transfer (CRT) transactions

March 20, 2026

On March 19, 2026, the US federal banking regulators issued several notices of proposed rulemakings (the "NPRs") implementing the final Basel III capital standards, otherwise known as the "Basel Endgame". The NPRs collectively represent a "do-over" of the original "Basel Endgame" proposal that was issued in July of 2023 (the "Original NPR"), which would have had profound effects on the ability of large banks to execute credit risk transfer ("CRT") (also known as significant risk transfer) trades for capital management purposes. 

Below, we summarize key aspects of the NPRs that are of particular relevance to the US CRT market and highlight areas where they differ from the Original NPR. We anticipate that today's developments will be of welcome news to most bank issuers, investors and other market participants in US CRT trades, though significant unresolved points remain outstanding. 

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