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PODCAST · 19 AUGUST 2026

CRD VI: Article 21c Post-transposition (Podcast)

Rob Cain and Sarah Thompson examine the implications of Ireland's transposition of CRD VI Article 21c, focusing on cross-border lending challenges, reverse solicitation exemptions, and grandfathering provisions.

IrelandFinance and Banking

In this episode of our podcast, Rob Cain, Partner, and Sarah Thompson, Partner and Head of the Financial Regulation Group, discuss the implications of the recent Irish transposition of CRD VI, with a particular focus on Article 21c and its impact on cross-border lending into Ireland.

Rob and Sarah examine key issues arising under the new regime, including the operation of the reverse solicitation exemption, the Irish transposing measures and the practical challenges facing third-country institutions providing financing to Irish borrowers. They also explore the developing market approach to grandfathering, lifecycle events and amendments to existing lending arrangements, considering the wider implications across a range of sectors, including funds, aviation finance and structured finance.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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