The FCA has invited us to provide swift informal feedback on the use of “no data” response options in securitisation reporting as they develop consultation proposals for publication early next year.
At the same time, the PRA has launched its consultation on securitisation capital requirements, covering possible approaches to the operation of the output floor, to method hierarchies, and (in a limited way, in relation only to synthetic securitisations) to the scope of the STS/STC framework. The discussion paper (DP3/23) can be found here, and the consultation closes on 31 January 2024.
We have reached out directly to our CMBS interest group about both of the above, but would (as always) be happy to hear from others who would like to contribute – contact Peter.
Meanwhile, we were cosignatories, alongside UK Finance and lead association AFME in a 30 October 2023 joint response to earlier UK PRA and FCA consultations on the draft rules relating to the regulation of securitisation in the post-Brexit world. The CREFC Europe CMBS interest group were kept in the loop throughout and had every opportunity to feed into the submission, and we’re grateful to Maria Green at A&O for her guidance and coordination.
