Ashurst LLP

We do not address costs specifically. Our response concentrates on legal issues.
Our response letter sets out particular difficulties for non-EU vehicles, such as repackaging issuers - see paragraphs 2 and 3. We also highlight difficulties with concentration limites for certain equity finance transactions - see paragraphs 4 and 5 of the attached response.
We do not address covered bond vehicles.
We do not address the proposed standards on models - our attached response concentrates on legal issues.
Our response highlights the difficulties the proposed concentration limits raise for certain equity finance transactions. See paragraphs 4 and 5.
Our response concentrates on the legal issues surrounding re-use of margin. We highlight one particular example (equity finance transactions) but this is not exhaustive. The ability to re-use margin can be essential to structuring many bespoke financing arrangements.
Ashurst LLP