20. September 2016
Comments on BCBS and IOSCO Consultative Document Criteria for identifying simple, transparent and comparable securitisations (BCBS 304)
We welcome the initiative of the Basel Committee on Banking Supervision and the International Organisation of Securities Commissions to define criteria for identifying simple, transparent and comparable securitisations. In particular, we consider it important to reconcile the perspectives of the financial services sector, of investors and of regulatory authorities when identifying and developing such criteria. Notwithstanding the EBA's parallel initiative in this respect, we expressly welcome the establishment of a uniform catalogue of criteria at the level of the Basel Committee – thus creating the fundamental basis for a harmonised implementation of such criteria across all countries recognising the securitisation framework defined by the Basel Committee.