Securitisation is an important and attractive source of funding for non-financial companies (NFCs). It provides NFCs with an alternative source of funding to bank loans and other capital market instruments such as bonds.
In principle the ACT agrees with the identification broad criteria, namely Simplicity, Transparency and Standardisation. However, we would encourage the EU to structure the identification criteria for qualifying securitisation based on liberal, broad parameters rather than specific, detailed rules.
Increased compliance costs will not encourage the revival of the European securitisation markets. Given that attracting international investments is one of the objectives of the CMU, the criteria should also facilitate investment from outside the EU rather than applying concepts that are only relevant in the EU.
Additional comments on short term securitisation, synthetic securitisation etc. can be found in the attachment below.