Submission #9

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Prime Collateralised Securities (PCS) EU

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 paper

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? No - see detailed paper

Q3: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for auto loans and leases? No - see detailed paper

Q4: Do you agree with the proposed amendment in Article 1 to the “type of obligor” for credit card receivables? No - see detailed paper

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. Yes - see detailed paper

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

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? No

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

Q9: Are there any important and severe unintended consequences of the application of the homogeneity criteria as specified in these RTS? No

Upload files Homogeneity PCS Response .pdf

Name of the organization Prime Collateralised Securities (PCS) EU