Response to consultation paper on draft RTS on the homogeneity of the underlying exposures in STS securitisation

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Q1: Do you agree with the proposed amendment to the asset category in Article 1 with respect to the addition of “credit facilities provided to enterprises, where the originator applies the same credit risk assessment approach as for individuals not covered under points (i), (ii) and (iv) to (viii)”? Please elaborate on the practical relevance.

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q2: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for credit facilities, including loans and leases, provided to any type of enterprise or corporation?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q3: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for auto loans and leases?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q4: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for credit card receivables?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q5: Do you see the need for the grandfathering provisions in Article 2 for the outstanding STS ABCP and STS non-ABCP securitisations? If yes, please elaborate.

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q6: Do you agree with the deferred application date in Article 2 for the outstanding STS on-balance-sheet securitisations?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q7: Are there any aspects that should be considered with regard to the homogeneity of the STS on-balance-sheet securitisations which are not specified in these RTS?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q8: Are there any impediments or practical implications of the criteria as defined in these draft RTS for STS traditional securitisations?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

Q9: Are there any important and severe unintended consequences of the application of the homogeneity criteria as specified in these RTS?

Please see uploaded file titled "AFME Response (25.10.2022) - EBA consultation on homogeneity".

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Name of the organization

AFME