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Thomas Ziesenitz
Typ av användare
Business association
Association of German Public Banks (Bundesverband Öffentlicher Banken Deutschlands - VÖB)
Organisationens storlek
Medium (50 to 249 employees)

Dear Sir or Madam

We explicitly welcome the opportunity to comment on the Commission's Draft Delegated Regulation concerning revised calibrations for securitisation investments by insurance and reinsurance undertakings under Solvency II.

It is our point of view, that the classification of fully supported ABCP securitisations as other securitisation positions does not reflect the low risk profile of fully supported ABCP
securitisations compared to the more risk-sensitive approach of STS
securitizations. We therefore advocate that fully supported ABCP
securitisations should be treated similar to STS securitisations in the
Commission's amendment proposal above, even if they did not achieve STS

Please find attached our positionpaper.

Yours sincerely
Thomas Ziesenitz

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