On January 31st, the IIF and ISDA (jointly referred to as the Associations), submitted the industry response to the BCBS consultation: Technical Amendment - Hedging of counterparty credit risk exposures. While we appreciate the work being undertaken by the BCBS, the Associations and our members have a number of concerns with the proposals. We do not believe the proposed change in the treatment of counterparty credit risk hedges is warranted given that the current substitution method is already very conservative. The Associations note that the calibration of the SA-CCR potential future exposure (PFE) multiplier calibration is too conservative based on available data. The proposed narrowly focused alignment between the recognition of collateral and guarantees (or credit derivatives) fails to establish a consistent treatment. Consequently, given these concerns, the Associations recommend that the Committee does not extend the application of the PFE multiplier to the recognition of credit derivatives or guarantees and, by extension, does not apply the corresponding methodology to exposures calculated under IMM. Any extension should only be considered after a review of the calibration of the PFE multiplier. Also we recommend a review of the potential alignment of credit risk mitigation between guarantees (or credit derivatives) and collateral as suggested in our letter to ensure that credit risk mitigation remains a viable tool for banks to manage counterparty credit risk exposures.