In this section you can find responses we have submitted (in some cases jointly with other industry associations) to consultations organised by government bodies or other organisations along with links to the underlying consultation documents.
2020 |
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20 November | Our submission to HMRC about proposed changes to the UK's rules for VAT grouping can be see here. |
3 November | Our joint submission alongside AFME and UK Finance in response to the UK FCA's consultation on the 'onshoring' of certain aspects of the European securitisation framework post Brexit can be seen here. |
7 July | Our representations on the European Commission's CMU road map action plan can be seen here. |
16 March | Our representations in response to the ESMA consultation paper on Guidelines on securitisation repository data completeness and consistency thresholds (ESMA 33-128-827) can be seen here. |
7 January | Our response to the UK Business Department's consultation on the future trajectory of minimum energy efficiency standards for the non-domestic private rented sector can be seen here. |
2019 |
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5 July | Our consolidated comments to ESMA on its 31 January 2019 draft securitisation disclosure templates and associated documents can be seen here. |
3 July | Our letter to the UK's HMRC on the Qualifying Private Placement Regulations 2015/2002 in relation to lender assignments can be seen here. |
8 January | We were among the contributors to a joint trade associations letter to ESMA regarding its securitisation disclosure technical standards ahead of a call on 9 January, which can be seen here. |
2018 |
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23 October | We made further submissions to ESMA in relation to its securitisation disclosure technical standards, which can be seen here. |
8 June | Our representations to the European Commission’s consultation on credit servicers, credit purchasers and the recovery of collateral can be seen here. |
19 March | Our response to ESMA's consultation on technical standards on disclosure requirements, operational standards and access conditions under the Securitisation Regulation. |
16 February | Our submission in response to the UK HM Revenue & Customs consultation on the taxation of gains made by non-residents on UK immovable property. |
13 February | We made a supplementary submission to the European Commission regarding the treatment of CMBS under the Solvency II standard formula (in the light of new BAML research). |
2017 |
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15 December | We made a submission to the European Commission regarding the treatment of CMBS under the Solvency II standard formula (in the light of relevant BAML research) |
23 October | Read our response to the European Commission's consultation on secondary markets for NPLs and the protection of secured creditors |
13 September | We made a submission to the EBA setting out consolidated feedback from members on EBA mandates under the Securitisation regulation and related CRR Amendment Regulation |
24 May | Our response to EIOPA's request for input regarding the treatment of unlisted equity and debt without an ECAI rating in the standard formula under Solvency II |
23 March | Our response to the European Commission's Capital Markets Union mid-term review |
23 February | Our response to the UK HM Revenue & Customs publication of draft Finance Bill clauses relating to the tax deductibility of corporate interest expense |
3 February | Our response to the OECD's discussion draft on non-CIV examples (BEPS Action 6) |
2016 |
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18 October | Our submissions in response to the European Commission's review of the macro-prudential policy framework can be seen here |
18 October | Our letter to Dr Paul Tang, CMU Rapporteur (European Parliament ECON Committee), regarding commercial real estate debt and securitisation in Europe |
16 August | Our response to the OECD's discussion draft on elements of the design and operation of the group ratio rule (BEPS Action 4) |
12 August | Our joint response (with the British Property Federation) to the UK HM Revenue & Customs review on the double tax treaty passport scheme review |
24 June | Our joint response (with CRE Finance Council) to the Basel Committee on its consultation on reducing variation in credit risk-weighted assets – constraints on the uses of internal model approaches |
22 April | Our submission to a consultation on the entitlement to treaty benefits of “non-CIV funds” sought to make the case for a sympathetic approach to CRE debt funds and cross-border securitisation issuers. |
11 March | Joint response to the Basel Committee’s second consultative document on proposed revisions to the Standardised Approach to credit risk, alongside the Association of Property Lenders in the UK and the CRE Finance Council in the US |
5 February | Response to the BCBS consultative document on capital treatment for "simple, transparent and comparable" securitisation, arguing that some of the proposed criteria for better capital treatment are misconceived and would inappropriately hinder securitisation of CRE debt. |
2 February | Our representations to HM Revenue & Customs on proposals relating to the taxation of carried interest - certain aspects of the proposals are problematic from the point of view of CRE debt funds - can be seen here |
27 January | Response to the European Commission's call for evidence on the regulatory framework for financial services. |
14 January | We have submitted our response to HM Treasury’s consultation on the UK’s implementation of proposals to restrict interest deductibility by reference to EBITDA. Those proposals emerged from the OECD’s base erosion and profit shifting (BEPS) project, targeting international tax avoidance, and pose quite serious threats to the CRE industry. They are also being explored at the EU level by the European Commission, as part of its revived common consolidated corporate tax base (CCCTB) initiative. |
2015 |
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13 August | CREFC Europe calls for a data and evidence based approach from regulators in response to EBA’s consultation on ‘slotting’ |
19 June | Our response to an OECD consultation on a revised discussion draft about their proposals for combatting treaty abuse (BEPS Action 6) |
19 June | Response to the European Banking Authority’s consultation on limiting the exposure of EU banks to shadow banking entities |
20 May | Response to ESMA’s Call for Evidence about CRA3 disclosure requirements for private and bilateral SFIs |
15 May | Response to the European Commission's STS securitisation consultation paper |
15 May | Response to European Commission’s Capital Markets Union green paper |
30 March | Response to BCBS consultation on revisions to the standardised approach for credit risk |
27 February | Joint response with BPF to HMRC's technical note on withholding tax and private placements |
13 February | Response to the BCBS-IOSCO consultation on proposed criteria for identifying simple, transparent and comparable securitisations |
16 January | Response to the European Banking Authority’s consultation on criteria for defining ‘simple standard and transparent’ securitisation |
16 January | Response to the OECD consultation on treaty abuse (BEPS Action 6) |
2014 |
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29 August | Response to the Bank of England’s May 2014 discussion paper Should the availability of UK credit data be improved? |
26 August | Response to the Central Bank of Ireland’s consultation paper on allowing “qualifying investor” alternative investment funds (AIF) to originate loans |
4 July | Response to joint BoE ECB discussion paper on qualifying securitisation |
July | Participation in a European Real Estate Forum request for an Urban Intergroup in the new European Parliament |
23 May | Participation in an industry letter to OECD’s treaty abuse consultation (BEPS Action 6) |
24 March | Participation in a joint trades submission in response to BCBS269 on revisions to the Basel securitisation framework |
21 March | Response to EBA securitisation questionnaire |
January | Joint submission with INREV to the European insurers regulator, EIOPA, commenting on the proposed treatment of CMBS under Solvency II |
Events
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CREFC US January Conference – Paving the Path Forward - Secure your complimentary pass
- 20 January 2021
- United Kingdom

Outlook for UK Real Estate Finance in 2021
- 28 January 2021
- Webinar
- United Kingdom