Submission #3

Association for Financial Markets in Europe (AFME)

Question 1: Do stakeholders agree with the amendments for Delegated Regulation (EU) No 2251/2016 suggested in this CP? please see the attached letter

Question 2: Are there any additional or alternative requirements for securitisations that stakeholders view should be introduced in Delegated Regulation (EU) No 2251/2016 following the amended mandate in Article 11(15) of EMIR? please see the attached letter

Question 3: Do stakeholders consider that the condition in draft Article 30a(2)(a) results in a treatment consistent with that provided in Article 30(2)(b) of Delegated Regulation (EU) No 2251/2016? please see the attached letter

Question 4: Do stakeholders consider that the non consideration of the waiver of the pari-passu rank, in conjuction with the minimum 2% credit enhancement, results in a similar protection of the OTC counterparty in the cases of STS securitisations as in the case of covered bonds? Or would it instead be necessary to retain the waiver currently available for covered bonds also for exceptional situations under STS securitisations? please see the attached letter

File Upload AFME response to ESAs Consultation to amend RTS under EMIR - 13 June 2018.pdf

Name of organisation Association for Financial Markets in Europe (AFME)