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.
Yes - see detailed paperQ2: 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?
No - see detailed paperQ3: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for auto loans and leases?
No - see detailed paperQ4: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for credit card receivables?
No - see detailed paperQ5: 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.
Yes - see detailed paperQ6: Do you agree with the deferred application date in Article 2 for the outstanding STS on-balance-sheet securitisations?
Yes - see detailed paperQ7: 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?
NoQ8: Are there any impediments or practical implications of the criteria as defined in these draft RTS for STS traditional securitisations?
Yes - see detailed paperQ9: Are there any important and severe unintended consequences of the application of the homogeneity criteria as specified in these RTS?
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Homogeneity PCS Response .pdf
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