CRD VI: What Does It Mean For U.S. Banks Lending Into Europe?

IN BRIEF

• January 2027 sees the introduction of CRD VI across Europe, which is potentially going to have a chilling effect on cross-border lending by non-European banks into the EU.
• US banks without either a European branch or subsidiary are going to be particularly affected and will need to reconfigure their European loan book in order to continue to lend compliantly.
• This article examines how those reconfigurations might look, operating within the exemptions set out in CRD VI, and also looks at the scope of reverse solicitation.