CREFC Europe - Consultations

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.

2022
18 February	Our response to the Central Bank of Ireland's consultation CP145 on macroprudential measures for the property fund sector will be available here once submitted.
2021
30 September	Our response to the European Commission's full consultation on DEBRA ('debt equity bias reduction allowance') can be seen here.
17 September	Our complete (supplemental and response form) submissions to the European Commission's targeted consultation on the functioning of the EU securitisation framework can be seen here.
9 September	Our response to CP21-17, the UK Financial Conduct Authority's consultation on enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers can be seen here.
2 September	Our response to HM Treasury's call for evidence in its review of the securitisation regulation can be seen here.
12 July	Our feedback on the European Commission's Roadmap on DEBRA ('debt-equity bias reduction allowance') can be seen here.
25 June	Our response to the consultation of the UK Financial Conduct Authority on a new authorised fund regime for investing in long term assets can be seen here.
9 June	Our response to the UK Department for Business, Energy and Industrial Strategy consultation on implementation of the EPC B future target for the non-domestic private rented sector can be seen here.
9 June	Our response to the UK Department for Business, Energy and Industrial Strategy consultation on performance based ratings for large commercial and industrial buildings in England and Wales can be seen here.
30 April	Our response to the call for evidence of the UK's Ministry of Housing, Communities and Local Government on commercial rents and covid can be seen here.
20 April	Our response to HM Treasury's call for input on the UK's funds regime can be seen here.
31 March	Our response to the RICS independent panel review of investment property valuations can be seen here.
23 February	Our response HM Treasury's second consultation on asset holding companies (AHCs) can be seen here.
29 January	Our response to the European Commission's public consultation on the review of the AIFMD can be seen here.
2020
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
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
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
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
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
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
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