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.

2019
09 Jan We participated in ESMA’s trade associations call regarding its securitisation disclosure technical standards and made certain related submissions by email
08 Jan We were among the contributors to a joint trade associations letter to ESMA regarding its securitisation disclosure technical standards ahead of a call on 9 January
2018
23 Oct We made further submissions to ESMA in relation to its securitisation disclosure technical standards
08 Jun Our response to the European Commission’s consultation  on credit servicers, credit purchasers and the recovery of collateral
19 Mar Our response to ESMA’s consultation on technical standards on disclosure requirements, operational standards and access conditions under the Securitisation Regulation
16 Feb Our submission in response to the UK HM Revenue & Customs consultation on the taxation of gains made by non-residents on UK immovable property
13 Feb We made a supplementary submission to the European Commission regarding the treatment of CMBS under the Solvency II standard formula (in the light of new BAML research)
2017
15 Dec We made a submission to the European Commission regarding the treatment of CMBS under the Solvency II standard formula (in the light of relevant BAML research)
23 Oct Our response to the European Commission’s consultation on secondary markets for NPLs and the protection of secured creditors
13 Sep We made a submission to the EBA setting out consolidated feedback from members on EBA mandates under the Securitisation regulation and related CRR Amendment Regulation
24 May Our response to EIOPA’s request for input regarding the treatment of unlisted equity and debt without an ECAI rating in the standard formula under Solvency II
23 Mar Our response to the European Commission’s Capital Markets Union mid-term review
23 Feb Our response to the UK HM Revenue & Customs publication of draft Finance Bill clauses relating to the tax deductibility of corporate interest expense
03 Feb Our response to the OECD’s discussion draft on non-CIV examples (BEPS Action 6)
2016
18 Oct Our submissions in response to the European Commission’s review of the macro-prudential policy framework
18 Oct Our letter to Dr Paul Tang, CMU Rapporteur (European Parliament ECON Committee), regarding commercial real estate debt and securitisation in Europe
16 Aug Our response to the OECD’s discussion draft on elements of the design and operation of the group ratio rule (BEPS Action 4)
12 Aug Our joint response (with the British Property Federation) to the UK HM Revenue & Customs review on the double tax treaty passport scheme review
23 Jun Our joint response (with CRE Finance Council) to the Basel Committee on its consultation on reducing variation in credit risk-weighted assets –
constraints on the uses of internal model approaches
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.
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 Mar Participation in a joint trades submission in response to BCBS269 on revisions to the Basel securitisation framework
21 Mar Response to EBA securitisation questionnaire
Jan Joint submission with INREV to the European insurers regulator, EIOPA, commenting on the proposed treatment of CMBS under Solvency II