Consultations

In this section you can find responses we have submitted (in some cases jointly with other industry associations) to consultations organised by government bodies or other organisations along with links to the underlying consultation documents.

2016
03 Jun Our Preliminary reactions to Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches (issued for comment by 24 June 2016)
22 Apr Our submission to a consultation on the entitlement to treaty benefits of “non-CIV funds” sought to make the case for a sympathetic approach to CRE debt funds and cross-border securitisation issuers.
11 Mar Joint response to the Basel Committee’s second consultative document on this subject, alongside the Association of Property Lenders in the UK and the CRE Finance Council in the US.
5 Feb Response to the BCBS consultative document on capital treatment for “simple, transparent and comparable” securitisation, arguing that some of the proposed criteria for better capital treatment are misconceived and would inappropriately hinder securitisation of CRE debt.
2 Feb
We have submitted representations to HM Revenue & Customs on proposals relating to the taxation of carried interest – certain aspects of the proposals are problematic from the point of view of CRE debt funds.  You can see our submission here.  Many thanks to those who contributed.
27 Jan Response to the European Commission’s call for evidence on the regulatory framework for financial services.
14 Jan We have submitted our response to HM Treasury’s consultation on the UK’s implementation of proposals to restrict interest deductibility by reference to EBITDA.  Those proposals emerged from the OECD’s base erosion and profit shifting (BEPS) project, targeting international tax avoidance, and pose quite serious threats to the CRE industry.  They are also being explored at the EU level by the European Commission, as part of its revived common consolidated corporate tax base (CCCTB) initiative.
2015
13 Aug CREFC Europe calls for a data and evidence based approach from regulators in response to EBA’s consultation on ‘slotting’
19 Jun Response to an OECD consultation on a revised discussion draft about their proposals for combatting treaty abuse (BEPS Action 6)
19 Jun Response to the European Banking Authority’s consultation on limiting the exposure of EU banks to shadow banking entities
20 May Response to ESMA’s Call for Evidence about CRA3 disclosure requirements for private and bilateral SFIs
 15 May Response to the European Commission’s STS securitisation consultation paper
15 May Response to European Commission’s Capital Markets Union green paper
 30 Mar Response to BCBS consultation on revisions to the standardised approach for credit risk
27 Feb Joint response with BPF to HMRC’s technical note on withholding tax and private placements
13 Feb Response to the BCBS-IOSCO consultation on proposed criteria for identifying simple, transparent and comparable securitisations
 16 Jan Response to the European Banking Authority’s consultation on criteria for defining ‘simple standard and transparent’ securitisation
16 Jan Response to the OECD consultation on treaty abuse (BEPS Action 6)
2014
29 Aug Response welcoming the Bank of England’s May 2014 discussion paper Should the availability of UK credit data be improved?
26 Aug Response to the Central Bank of Ireland’s consultation paper on allowing “qualifying investor” alternative investment funds (AIF) to originate loans
24 Aug Response to Bank of England’s discussion paper Should the availability of UK credit data be improved?
4 Jul Response to joint BoE ECB discussion paper on qualifying securitisation
Jul Participation in a European Real Estate Forum request for an Urban Intergroup in the new European Parliament
23 May Participation in an industry letter to OECD’s treaty abuse consultation (BEPS Action 6)
24 March Participation in a joint trades submission in response to BCBS269 on revisions to the Basel securitisation framework
21 March Response to EBA securitisation questionnaire
January Joint submission with INREV to the European insurers regulator, EIOPA, commenting on the proposed treatment of CMBS under Solvency II