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Published Results: securitisation-2015

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What is your role in securitisation markets?(role-in-securitisation)
Please specify what other role you have in securitisation markets:(other-role-in-securitisation)
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Please specify your activity field(s) or sector(s):(specify-activity-field)
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A. Do the identification criteria need further refinements to reflect developments taking place at EU and international levels? If so, what adjustments need to be made?(identification-criteria-further-refinements)
B. What criteria should apply for all qualifying securitisations (“foundation criteria”)?(qualifying-securitisation-framework)
A. To what extent should criteria identifying simple, transparent, and standardised short-term securitisation instruments be developed? What criteria would be relevant?(criteria-development)
B. Are there any additional considerations that should be taken into account for short-term securitisations?(additional-considerations-short-term-securitisations)
A. Are there elements of the current rules on risk retention that should be adjusted for qualifying instruments?(responsibility-risk-retention-requirements-remain-on-investors)
B. For qualifying securitisation instruments, should responsibility for verifying risk retention requirements remain with investors (i.e. taking an “indirect approach”)? Should the onus only be on originators? If so, how can it be ensured that investors continue to exercise proper due diligence?(other-aspects-risk-retention-requirements)
A. How can proper implementation and enforcement of EU criteria for qualifying instruments be ensured?(implementation-enforcement-ensured)
B. How could the procedures be defined in terms of scope and process?(procedures-definition)
C. To what extent should risk features be part of this compliance monitoring?(risk-features-in-monitoring)
A. What impact would further standardisation in the structuring process have on the development of EU securitisation markets?(further-standardisation-impact)
B. Would a harmonised and/or optional EU-wide initiative provide more legal clarity and comparability for investors? What would be the benefits of such an initiative for originators?(framework-increase-safety)
C. If pursued, what aspects should be covered by this initiative (e.g. the legal form of securitisation vehicles; the modalities to transfer assets; the rights and subordination rules for noteholders)?(aspects-covered-by-initiative)
D. If created, should this structure act as a necessary condition within the eligibility criteria for qualifying securitisations?(framework-necessary-condition)
A. For qualifying securitisations, what is the right balance between investors receiving the optimal amount and quality of information (in terms of comparability, reliability, and timeliness), and streamlining disclosure obligations for issuers/originators?(qualifying-securitisations-right-balance)
B. What areas would benefit from further standardisation and transparency, and how can the existing disclosure obligations be improved?(areas-benefit-from-standardisation)
C. To what extent should disclosure requirements be adjusted – especially for loan-level data – to reflect differences and specificities across asset classes, while still preserving adequate transparency for investors to be able to make their own credit assessments?(improve-transparency-and-disclosure)
A. What alternatives to credit ratings could be used, in order to mitigate the impact of the country ceilings employed in rating methodologies and to allow investors to make their own assessments of creditworthiness?(alternatives-to-credit-ratings)
B. Would the publication by credit rating agencies of uncapped ratings (for securitisation instruments subject to sovereign ceilings) improve clarity for investors?(publication-improve-clarity)
A. For qualifying securitisations, is there a need to further develop market infrastructure?(further-develop-dedicated-market-infrastructure)
B. What should be done to support ancillary services? Should the swaps collateralisation requirements be adjusted for securitisation vehicles issuing qualifying securitisation instruments?(support-to-current-market-practices)
C. What else could be done to support the functioning of the secondary market?(relevant-issues-in-existing-legislation)
With regard to the capital requirements for banks and investment firms, do you think that the existing provisions in the Capital Requirements Regulation adequately reflect the risks attached to securitised instruments?(exposures-existing-provisions)
If changes to EU bank capital requirements were made, do you think that the recent BCBS recommendations on the review of the securitisation framework constitute a good baseline? What would be the potential impacts on EU securitisation markets?(bcbs-recommendations)
How should rules on capital requirements for securitisation exposures differentiate between qualifying securitisations and other securitisation instruments?(rules-differentiated)
Given the particular circumstances of the EU markets, could there be merit in advancing work at the EU level alongside international work?(eu-prevail-over-internationally-agreed-approaches)
Are there wider structural barriers preventing long-term institutional investors from participating in this market?  If so, how should these be tackled?(refine-calibrations)
A. For insurers investing in qualifying securitised products, how could the regulatory treatment of securitisation be refined to improve risk sensitivity? For example, should capital requirements increase less sharply with duration(regulatory-treatment-refined)
B. Should there be specific treatment for investments in non-senior tranches of qualifying securitisation transactions versus non-qualifying transactions?(specific-treatment-for-investments)
A. How could the institutional investor base for EU securitisation be expanded?(base-for-instruments-development)
B. To support qualifying securitisations, are adjustments needed to other EU regulatory frameworks (e.g. UCITS, AIFMD)? If yes, please specify.(adjustments-to-other-eu-regulatory-frameworks)
A. What additional steps could be taken to specifically develop SME securitisation?(develop-securitisations-with-sme-exposures)
B. Have there been unaddressed market failures surrounding SME securitisation, and how best could these be tackled?(further-standardisation)
C. How can further standardisation of underlying assets/loans and securitisation structures be achieved, in order to reduce the costs of issuance and investment?(more-standardisation)
D. Would more standardisation of loan level information, collection and dissemination of comparable credit information on SMEs promote further investment in these instruments?(more-standardisation-promote-investment)
To what extent would a single EU securitisation instrument applicable to all financial sectors (insurance, asset management, banks) contribute to the development of the EU’s securitisation markets? Which issues should be covered in such an instrument?(single-eu-securitisation-instrument)
A. For qualifying securitisation, what else could be done to encourage the further development of sustainable EU securitisation markets?(what-else-qualifying-securitisation-markets)
B. In relation to the table in Annex 2 are there any other changes to securitisation requirements across the various aspects of EU legislation that would increase effectiveness or consistency?(what-else-non-qualifying-securitisation-markets)
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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Are you replying as:
First name and last name:
Name of your organisation:
Name of the public authority:
Contact email address:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Type of organisation:
Please specify the type of organisation:
Type of public authority
Please specify the type of public authority:
Where are you based and/or where do you carry out your activity?
Please specify your country:
What is your role in securitisation markets?
Please specify what other role you have in securitisation markets:
Field of activity or sector (if applicable):
Please specify your activity field(s) or sector(s):
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement PDF)
A. Do the identification criteria need further refinements to reflect developments taking place at EU and international levels? If so, what adjustments need to be made?
B. What criteria should apply for all qualifying securitisations (“foundation criteria”)?
A. To what extent should criteria identifying simple, transparent, and standardised short-term securitisation instruments be developed? What criteria would be relevant?
B. Are there any additional considerations that should be taken into account for short-term securitisations?
A. Are there elements of the current rules on risk retention that should be adjusted for qualifying instruments?
B. For qualifying securitisation instruments, should responsibility for verifying risk retention requirements remain with investors (i.e. taking an “indirect approach”)? Should the onus only be on originators? If so, how can it be ensured that investors continue to exercise proper due diligence?
A. How can proper implementation and enforcement of EU criteria for qualifying instruments be ensured?
B. How could the procedures be defined in terms of scope and process?
C. To what extent should risk features be part of this compliance monitoring?
A. What impact would further standardisation in the structuring process have on the development of EU securitisation markets?
B. Would a harmonised and/or optional EU-wide initiative provide more legal clarity and comparability for investors? What would be the benefits of such an initiative for originators?
C. If pursued, what aspects should be covered by this initiative (e.g. the legal form of securitisation vehicles; the modalities to transfer assets; the rights and subordination rules for noteholders)?
D. If created, should this structure act as a necessary condition within the eligibility criteria for qualifying securitisations?
A. For qualifying securitisations, what is the right balance between investors receiving the optimal amount and quality of information (in terms of comparability, reliability, and timeliness), and streamlining disclosure obligations for issuers/originators?
B. What areas would benefit from further standardisation and transparency, and how can the existing disclosure obligations be improved?
C. To what extent should disclosure requirements be adjusted – especially for loan-level data – to reflect differences and specificities across asset classes, while still preserving adequate transparency for investors to be able to make their own credit assessments?
A. What alternatives to credit ratings could be used, in order to mitigate the impact of the country ceilings employed in rating methodologies and to allow investors to make their own assessments of creditworthiness?
B. Would the publication by credit rating agencies of uncapped ratings (for securitisation instruments subject to sovereign ceilings) improve clarity for investors?
A. For qualifying securitisations, is there a need to further develop market infrastructure?
B. What should be done to support ancillary services? Should the swaps collateralisation requirements be adjusted for securitisation vehicles issuing qualifying securitisation instruments?
C. What else could be done to support the functioning of the secondary market?
With regard to the capital requirements for banks and investment firms, do you think that the existing provisions in the Capital Requirements Regulation adequately reflect the risks attached to securitised instruments?
If changes to EU bank capital requirements were made, do you think that the recent BCBS recommendations on the review of the securitisation framework constitute a good baseline? What would be the potential impacts on EU securitisation markets?
How should rules on capital requirements for securitisation exposures differentiate between qualifying securitisations and other securitisation instruments?
Given the particular circumstances of the EU markets, could there be merit in advancing work at the EU level alongside international work?
Are there wider structural barriers preventing long-term institutional investors from participating in this market?  If so, how should these be tackled?
A. For insurers investing in qualifying securitised products, how could the regulatory treatment of securitisation be refined to improve risk sensitivity? For example, should capital requirements increase less sharply with duration
B. Should there be specific treatment for investments in non-senior tranches of qualifying securitisation transactions versus non-qualifying transactions?
A. How could the institutional investor base for EU securitisation be expanded?
B. To support qualifying securitisations, are adjustments needed to other EU regulatory frameworks (e.g. UCITS, AIFMD)? If yes, please specify.
A. What additional steps could be taken to specifically develop SME securitisation?
B. Have there been unaddressed market failures surrounding SME securitisation, and how best could these be tackled?
C. How can further standardisation of underlying assets/loans and securitisation structures be achieved, in order to reduce the costs of issuance and investment?
D. Would more standardisation of loan level information, collection and dissemination of comparable credit information on SMEs promote further investment in these instruments?
To what extent would a single EU securitisation instrument applicable to all financial sectors (insurance, asset management, banks) contribute to the development of the EU’s securitisation markets? Which issues should be covered in such an instrument?
A. For qualifying securitisation, what else could be done to encourage the further development of sustainable EU securitisation markets?
B. In relation to the table in Annex 2 are there any other changes to securitisation requirements across the various aspects of EU legislation that would increase effectiveness or consistency?

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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