Comment Letters
As regulations and legislation develops in pace with the growth of the European securitisation industry, the ESF gives its members’ a unified voice by issuing official commentary on matters of concern to regulators and government. In addition, from time to time the ESF is invited by government or regulatory bodies to comment on their draft proposals and make suggestions for improvement. The ESF does so with a view to the success of its members’ in particular, and the prosperity of the European securitisation industry in general. Our comment letters are published in pdf format. Please download Adobe Reader here.
Most Recent
10 August, 2009
ESF/SIFMA response to IOSCO consultation on ABS offerings
The ESF and SIFMA letter filed to the International Organization of Securities Commissions (IOSCO) on the Consultation Report dealing with the Disclosure Principles for Public Offerings and Listings of Asset-Backed Securities.
23 February, 2009
Final Joint-Industry Response on CESR Bond Price Transparency Consultation Paper
The final response to CESR’s 19 December 2008 Consultation Paper on transparency of corporate bond, structured finance product and credit derivatives markets, submitted jointly by ICMA, ISDA, SIFMA, LIBA, EHYA, ESF and BBA. For any questions or comments, please contact Bertrand Huet.
31 October, 2007
Re: ESF Comments on Draft Law "On Amending Federal Law on Insolvency (Bankruptcy) of Credit Institutions" (the Draft Law)
The ESF’s Russia and Eastern Europe Working Group comments on the draft law "On Amending Federal Law on Insolvency (Bankruptcy) of Credit Institutions", under consideration by the Committee of the State Duma on Credit Organisations and Financial Markets. Issues are raised in regard to bankruptcy remoteness and the scope of the law, with a variety of specific suggestions for improvement made.
30 September, 2007
Joint Trade Associations’ Response European Commission Public Consultation on the reorganisation and winding up of Credit Institutions
The London Investment Banking Association (LIBA), the Futures and Options Association (FOA) and the ESF welcome this opportunity to comment at this early stage on the review of the Credit Institutions Winding-up Directive (CI WUD). In responding to this consultation we have addressed only those policy questions that are of particular interest to Members; we have not addressed any questions that relate to current legal fact.
23 August, 2007
Re: Preliminary Comments on Framework Solvency II Directive
The ESF’s Solvency II Working Group submits initial comments on the draft Solvency II framework directive. Forms of risk mitigation are discussed and evaluated, with suggestions made for their implementation in the directive. Recommendations are made regarding the appropriate level of prudential supervision required for SPVs.
12 January, 2007
Consultation Paper 19: Draft Advice to the European Commission in the Framework of the Solvency II Project on Safety Measures (Limits on Assets)
The ESF’s Solvency II Working Group comments on the FSA’s Consultation Paper 19 (CP05-06). It addresses the prudent person approach versus the prudent person plus approach and outlines the reasons. The difficulty in applying quantitative restrictions to ABS and securitisations is also discussed. Following this, specific commentary regarding Consultation Paper 19 is outlined.
