13 February 2015

EFAMA （欧州投資信託協会）、BCBS（バーゼル銀行監督委員会）・IOSCO（証券監督者国際機構）によるシンプルで透明性が高く比較可能な証券化商品の基準案へのコメントを公表、証券化市場の信頼を回復するには不十分と指摘

EFAMA presented its views on BCBS/IOSCO’s proposals for setting criteria which will facilitate the analysis of each securitized instrument by financial market participants in identifying securitization structures of greater transparency.

EFAMA believes that the proposed criteria are not sufficient to restore confidence and invest into securitised instruments. Several other elements should also be taken into account:

• The stability of the criteria and the stability of the values all along the life of the securitized instrument
• The need to standardize further regulations in order to reduce the regulatory obstacles to securitized products or to align their requirements with those applied to other asset classes like, for example, covered bonds
• The alignment of legislative requirements (e.g. some securitized instruments are allowed in UCITS but not in AIFMD) and the treatment of securitized instruments in the calculation of regulatory capital requirements for securitization positions which are significantly stricter

With regards to asset selection and transfer, EFAMA believes that the exclusion of actively managed assets is not appropriate. In EFAMA’s view, the proposed exclusion of actively managed assets or selected on a discretionary basis is not appropriate for the purpose of identifying STC securitisations. A portfolio which is actively managed by a regulated manager having a good track record is, from various perspectives, similar to a non‐actively managed portfolio made of assets having good performance history.

EFAMA further notes that the regulatory capital treatment for securitization positions put ABS bonds at a disadvantage compared to other asset classes like, for example, covered bonds and hence forms a major obstacle for the development of short‐term securitization markets.

Full position paper

© EFAMA - European Fund and Asset Management Association