Key points include:
- Finance Watch welcomes and supports the criteria proposed by BCBS/IOSCO to define simple, transparent and comparable securitisations, but is not convinced that they are enough, as they stand, to achieve their goals,
- among other things, stronger rules are needed to determine which type and minimum quality of underlying assets can be included in the definition,
- additional criteria should also be added, including that qualifying securitisations should not be allowed to use tranching,
- while short term securitisation has a role to play, we do not support the development of a qualifying framework for asset backed commercial paper.