The Voice of Commercial Real Estate Finance


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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.

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 AIFMDcan be seen here.
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.
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.
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).
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)
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.
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)
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


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