The pace of deals in the US “credit risk transfer” (CRT) market through the end of 2023 spurred expectations that the US market would catch up to its European “significant risk transfer” (SRT) counterpart, promising more deal volume, issuers and investors. While investor demand continues unabated and some new issuers have entered the market, the pace of growth is cautious, and many transactions are now executed in the form of bilateral CDS transactions that provide more certainty of execution and timing in comparison to CLNs issued by banks or SPVs sponsored by banks. At the same time, new questions are arising from a regulatory focus on bank-financed leverage to CRT trades and uncertainty about the future direction of the Basel capital framework.