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Rebecca Hansford
AFME comment on the Delegated Act for Solvency II adopted by the European Commission
10 Oct 2014
Commenting on the adoption by the European Commission of a Delegated Act containing implementing rules for Solvency II today, Sidika Ulker, Director, Capital Markets at the Association for Financial Markets in Europe (AFME), said: “There is much to welcome in the proposed Solvency II Delegated Act. To start with, this is the first official recognition by both the European Commission and EIOPA that high quality securitisation should receive a more favourable regulatory treatment. In addition, the Delegated Act deliberately seeks consistency with related regulations such as the definition of High Quality Liquid Assets for bank investors. Consistency is key in this context. “While these are positive steps, unfortunately key provisions of the Delegated Act mean that insurance companies will remain disincentivised to invest in high quality securitisation, which helps fund the real economy, for the following reasons: The charges for type 1 securitisations (AAA-rated), despite having been substantially reduced, remain too high: securitisation spreads will not be sufficient to make investments attractive once the capital charges are applied. The classification of all non-senior tranches as Type 2 securitisations creates severe cliff effects between the capital charge treatment of senior and non-senior securitisations. For example, the senior tranche of a 5-year AAA-rated RMBS would receive a capital charge of 10.5% and the non-senior would receive a charge of 67%. This distortion is even more marked for securitisations which require greater credit enhancement, such as SME securitisations. The concept of look-through, which aims to cap the capital charges for Type 1 to be no greater than 3% (the charge of underlying loans), will not be effective for mortgages. Direct investment in pools of mortgage loans will continue to receive significantly lower capital charge treatment, creating adverse investment incentives. For example, a 5 year AAA-rated RMBS will receive a capital charge of 10.5%; however, direct investment in a whole loan pool comprised of the same mortgages will receive a capital charge of just 0-3%. “Further, we believe, as the ECB and Bank of England have recognised, that if a securitisation is high quality, the whole transaction (not just the senior tranche) should be treated as such. We very much hope that the European Commission will review the treatment of securitisation at the first possible opportunity in order that Solvency II may truly achieve the broader objective of reviving the high quality securitisation market to help support growth in Europe.” -ENDS-
Rebecca Hansford
SIFMA and AFME Statement on Transatlantic Trade and Investment Partnership (TTIP)
13 Jun 2014
Washington, D.C. and London, June 13, 2014 – SIFMA President and CEO Kenneth E. Bentsen, Jr. and AFME CEO Simon Lewis today issued the following statement in response to remarks by Michel Barnier, European Commissioner for Internal Market and Services, at the Peterson Institute for International Economics regarding developments in US-EU financial services and a Transatlantic Trade and Investment Partnership (TTIP): “SIFMA and AFME believe it is imperative that financial services regulatory coordination be included as a key component of TTIP, and we commend Commissioner Barnier for his focus on this issue. A financial services regulatory framework between the US and EU would enhance coordination, reduce conflict and confusion, and improve the efficiency of regulations across borders. We urge policymakers to capitalize on this opportunity provided by TTIP to promote consistent high-quality regulatory standards in global markets and economies that are closely intertwined.” -30- The Securities Industry and Financial Markets Association (SIFMA) brings together the shared interests of hundreds of securities firms, banks and asset managers. SIFMA's mission is to support a strong financial industry, investor opportunity, capital formation, job creation and economic growth, while building trust and confidence in the financial markets. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org. The Association for Financial Markets in Europe advocates stable, competitive and sustainable European financial markets, which support economic growth and benefit society. AFME (Association for Financial Markets in Europe) promotes fair, orderly, and efficient European wholesale capital markets and provides leadership in advancing the interests of all market participants. AFME represents a broad array of European and global participants in the wholesale financial markets. Its members comprise pan-EU and global banks as well as key regional banks, brokers, law firms, investors and other financial market participants. AFME participates in a global alliance with the Securities Industry and Financial Markets Association (SIFMA) in the US, and the Asia Securities Industry and Financial Markets Association through the GFMA (Global Financial Markets Association). For more information please visit the AFME website, www.afme.eu.
Rebecca Hansford
AFME welcomes central banks’ pro‐securitisation report
30 May 2014
The Association for Financial Markets in Europe (AFME) has welcomed the discussion paper, ‘The case for a better functioning securitisation market in the European Union’, published today by the Bank of England (BoE) and the European Central Bank (ECB). “The paper summarises concisely what went wrong during the financial crisis, and helpfully acknowledges the steps already taken in Europe to address those shortcomings, as well as the strong performance of high‐quality securitisation in Europe,” commented Simon Lewis, Chief Executive, AFME. “Most importantly, the paper poses several interesting ideas for further discussion – most significantly, the concept of ‘qualifying securitisations’. This fits well with recent calls by the European Commission to revive a sustainable market for high‐quality securitisation in Europe, as well as the analysis currently being undertaken by the European Banking Authority. He added: “AFME and the industry are keen to continue our constructive engagement with the Bank, the ECB, the Commission and other policymakers to continue to develop this concept. Much work remains to be done, and there remain difficult challenges to resolve – for example, how to avoid cliff effects; how to address the different motives behind any single definition of ‘high quality’; and how to strike the right balance between meeting the needs of the real economy, while maintaining high quality. “We believe it is crucial for industry and policymaker discussions to converge in a single forum, where we can all work together in a co‐ordinated way. The prize will be an agreed standard that can be applied widely, usefully, easily and clearly to help revive European high‐quality securitisation.” ‐ENDS‐
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Rebecca O'Neill

Head of Communications and Marketing

+44 (0) 20 3828 2753