Joint Associations' response on criteria for identifying simple, transparent and comparable securitisations

On February 13, the IIF, GFMA, ICMA and ISDA (together, the Associations) responded to the BCBS-IOSCO consultative document "Criteria for identifying simple, transparent and comparable securitizations", commenting on the proposed 14 criteria that could be used to identify securitizations that lend themselves to less complex analysis and therefore could contribute to building sustainable securitization markets.

The Associations strongly support the efforts to develop criteria that will help to mitigate the impediments to functioning securitization markets, including eliminating the stigma attached to such markets and reducing the difficulty in assessing risks associated with securitization investments. ' However, the Associations consider there is further room to make the criteria more comprehensive and practical. Some of the recommendations made in the letter include the need to balance between the benefit of investor and originator, harmonization of the criteria across jurisdictions, inclusion of certain types of synthetic securitizations, and treatment of ABCP conduits under STC framework.