Guidance Note on Reverse Solicitation for Purposes of CRD VI (Aug 4 2026)

Under European Directive CRD VI, one of the principal exemptions on which lenders may seek to rely is “reverse solicitation”, where services are provided at “the own exclusive initiative” of the client rather than pursuant to marketing from the lender. The Guidance Note develops further on this key form of relief for market participants and includes various forms of language for consideration in different loan market documentation, including a form of “Special Notice regarding CRD VI” for inclusion in Confidential Information Memoranda and Lender Presentations, together with forms of optional representation for inclusion in Company Authorization Letters and engagement and/or commitment documentation. This Note was developed with the assistance of a dedicated working group comprised of members of the Primary Market Committee, including those institutions with a presence in the EU and those lacking such presence.

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  • CRD VI Reverse Solicitation Guidance Note_Final_04Aug26.docx 191 KB

Tess Virmani

General Counsel and EVP/Head of Policy

Elizabeth Yazgi

Assistant General Counsel

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