EuroABS Limited

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EuroABS agrees with the interpretation of this criterion and the statements provided in the consultation in paragraphs 87 and 88.

However, EuroABS considers that further useful clarification should be provided as follows:

1. The liability cash flow model must be fully transparent – all formulas and code must be available for inspection by the user so that it can be checked by the user and full confidence gained in the model.
2. The liability cash flow model must be available free of charge to investors, potential investors and the various regulatory authorities. These users should not be expected to pay to access regulatory disclosures.

In addition to these points, EuroABS considers that paragraph 87 could provide greater clarity if amended as follows:

87. For the purposes of Article 22(3) of Regulation (EU) 2017/2402, the representation of the contractual relationships between the underlying exposures and the payments flowing between the originator, sponsor, investors, other parties and the SSPE, should be considered to be done “precisely” where it is done in an accurate manner and with a sufficient amount of detail (with regard to rules, terms and amounts and to include all flows, including expenses, reserves, re-investments), enabling the investors to model payment obligations and structure of the SSPE and price the securitisation accordingly.""
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Ben Bates
E