Submission #13

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Leaseurope/Eurofinas

Question 1: Do you have any comments on this introductory section of the Discussion Paper? No

Question 2: Do you agree with the analysis on the market developments? Please provide any additional relevant information to complement the analysis. No

Question 3: Do you agree with the analysis of the historical performance? Please provide any additional relevant information to complement the analysis. No

Question 4: Do you agree with the analysis of the rationale for the creation of the STS synthetic instrument? How useful and necessary is synthetic securitisation for the originator and the investor? What are the possible hurdles for further development of the market? No

Question 5: Do you agree with the assessment of the reasons that could eventually support a preferential capital treatment? No

Question 6: Please provide any additional relevant information on potential impact of the creation of the STS synthetic securitisation on (STS) traditional securitisation, and any other information to complement the analysis. No

Question 7: Do you agree with the criteria on simplicity? Please provide comments on their technical applicability and relevance for synthetic securitisation. No

Question 8: Do you agree with the criteria on standardisation? Please provide comments on their technical applicability and relevance for synthetic securitisation. No

Question 9: Do you agree with the criteria on transparency? Please provide comments on their technical applicability and relevance for synthetic securitisation. No

Question 10: Do you agree with the specific criteria for synthetic securitisation? No

Question 11: Do you agree with the criterion 36 on eligible credit protection agreement, counterparties and collateral? Please provide any relevant information on the type of credit protection and different collateral arrangements used in market practice and their pros and cons for the protection of the originator and investor. No

Question 12: Please provide suggestions for any other specific criteria that should be introduced as part of the STS framework for simple, transparent and standardised securitisation. No

Question 13: Do you see a justification for possible introduction of a differentiated regulatory treatment of STS synthetic securitisation? If yes, what should be the scope of such treatment and how should it be structured - for example only for senior tranche retained by the originator bank, or more limited/wider? No

Question 14: What would be the impact if no differentiated regulatory treatment is introduced? In that case, is the introduction of the STS product without preferential treatment relevant for the market? No

Question 15: What would be the impact of potential differentiated regulatory treatment from level playing perspective with regard to third countries where STS framework has not been introduced? No

Question 16: Should a separate explicit recommendation be included in the Recommendations section on whether or not such treatment should be introduced? No

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Name of organisation Leaseurope/Eurofinas