Field 290 - First Foreseeable Termination Date. Firstly, if there is no call date and the clean-up date is not known (e.g. for an Investor position), what do we report here? Secondly, if there is a call date but this is now in the past (i.e. hasn't yet been called) what do we report here?
The guidelines state that the date reported here should be the earliest of a clean-up call or any other call option. If the position being reported here is an Investor position rather than Originator position the clean-up call date will not be known and some securitisations do not have a call date. In this case what is required to be reported in this field? Secondly, if the securitisation does have a call date but this is in the past, how should this be reported? In theory the securitisation could be called on any future Interest Payment Date.
Reporting of the First Foreseeable Termination Date in C 14.00 of Annex I of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS).
Question 1: Where the securitisation has neither a clean-up call or another call, then the First Foreseeable Termination Date shall be the Legal Final Maturity Date.
Question 2: In case a securitisation has a call but the call date is only in the past, then the First Foreseeable Termination Date shall be the Legal Final Maturity Date.