Amendments to the treatment of securitisation exposures under the Liquidity Coverage Ratio Delegated Regulation

Leaseurope, Eurofinas, True Sale International GmbH (TSI) and the German Banking Industry Committee (GBIC), expressly welcome the European Commission's initiative to revise the securitisation framework as a whole.

We welcome the Commissions June 17th holistic initiative for revitalizing the EU securitisation market and its clear willingness to act on several fronts to achieve the intended result; in particular, the determination to amend the LCR Delegated Regulation as regards the eligibility of securitisations in the liquidity buffer of banks is an essential move in the right direction.

The ASF (Association française des Sociétés Financières) brings together all specialized credit institutions: some 250 members with outstandings of 306 billion, or almost 18% of total French private-sector loans to the economy.

The German Banking Industry Committee (GBIC), True Sale International GmbH (TSI), Eurofinas and Leaseurope expressly welcome the European Commission's initiative to revise the securitisation framework as a whole.

The German Banking Industry Committee (GBIC), True Sale International GmbH (TSI), Eurofinas and Leaseurope expressly welcome the European Commission's initiative to revise the securitisation framework as a whole.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commissions call for feedback on targeted amendments to the Liquidity Coverage Ratio Delegated Regulation. Please find our feedback in the uploaded file.

We generally view favourably the EC proposals for amending the eligibility conditions for securitisations in the liquidity buffer of credit institutions. Combined with the proposals regarding CRR and the Securitisation Regulation, they make it more attractive for banks to diversify the LCR portfolios towards securitisations in the Level 2B bucket.

Crédit Agricole Group strongly welcomes the review of the Liquidity Coverage Ratio (LCR) Delegated Regulation and the European Commissions (EC) intention to find a better balance between stability and market development. Securitisation enhances credit circulation and reduces risk concentration by distributing it across diverse market participants.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on European Commission consultation on the draft Commission Delegated Regulation amending Delegated Regulation (EU) 2015/61 as regards the eligibility conditions for securitisations in the liquidity buffer of credit institutions.

While we agree that the double transformation creates a huge investment gap and that a higher investment ratio would be desirable in the current cyclical situation, we see the problem more in high uncertainty and subdued sales expectations. This is also shown by the ECB’s surveys on the access to finance (safe) regularly and most recently.

Filed in German · English published by the European Commission

We very much appreciate the European Commissions consultation paper to review the treatment of securitisations under the liquidity coverage ratio in order to foster the role of bank treasuries as investors of this instrument. The strengthening of the demand side of securitisations will lead to a more competitive securitisation market and, ultimately, to benefits to lending to the EU economy.

We welcome the Commissions proposed amendment to the LCR Delegated Act increasing the eligibility of senior tranches of STS traditional securitisations with credit quality CQS5 to CQS7as a first step in shifting away from the current treatment, which results overly conservative and deeply affects the market liquidity of those securities, in turn impacting their price and issuance volume, ultimately discouraging…

Dear Mr/ Ms. We thank you for the opportunity to commont on the amendments to the treatment of securitisations under the Liquidity Coverage Ratio Delegated Regulation. We strongly oppose the changes proposed to the Delegated Regulation for the liquidity coverage ratio.

On behalf of the Luxembourg Bankers Association (ABBL), we are pleased to submit our response to the European Commissions open Have Your Say process on the proposed review of the Securitisation Regulation (SECR) framework. The ABBL welcomes the Commissions initiative to review and enhance the SECR.

ESBG welcomes the European Commissions initiative to strengthen the securitisation market as a means to support the EUs broader strategic objectives. To motivate banks and other financial entities to invest in high-quality, low-risk EU asset-backed securities (ABS) is a key step toward normalizing demand in the securitisation market. This can help boost lending to the EUs real economy at more competitive rates.

Thank you for sharing the Amendments to the treatment of securitisation exposures under the LCR Delegated Regulation. We hereby share with you the feedback on behalf of De Nederlandsche Bank (DNB). We share the view of the Commission that it is important to facilitate funding of EU strategic objectives.

European Commission Consultation, as part of the Securitisation Package of 17 June, on amending Delegated Regulation (EU) 2015/61 as regards the eligibility conditions for securitisations in the liquidity buffer of credit institutions This document provides the response of the Dutch Securitisation Association (DSA) on the Consultation. We welcome the opportunity to respond on this Consultation.

Securitisation can allow banks to strengthen and increase their capability to provide more lending to the real economy, enabling them to free up regulatory capital which can be used to originate new loans, and it can contribute to a well-diversifying funding source.

We welcome the securitisation reform presented by the European Commission. AFG is especially supportive of the additional flexibility on the investor / regulatory reporting, and supportive of the reduced redundancy for due diligence. We would however warn on the proposed widened definition of public securitisation, which will have adverse effects.

Paris Europlace welcomes the reopening of the LCR Delegated Act, and fully concurs with the Commissions assessments that The eligibility of securitisations in the liquidity buffer is considered to be an important criterion for all market participants to invest in securitisations, as it enables them to find active counterparties on capital markets, including credit institutions, to trade their portfolios, and that…

Finance Denmark appreciates the opportunity to provide feedback regarding the amendments to the prudential treatment of securitisation exposures under the Liquidity Coverage Ratio Delegated Regulation. We support the Commissions initiative to revise the eligibility conditions for securitisations in the liquidity buffer of credit institutions.

While we support reducing issuer reporting burdens, redefining public securitisation based on EU listings risks unintended consequences. It may drive issuers to non-EU venues and misclassify private deals, undermining the SIUs goals. Clearer, risk-aligned criteria are essential to preserve market efficiency and the attractiveness as well as the integrity of EU financial infrastructures.

Treatment of STS securitisations and ABCPs for the LCR European Supervision Authorities have published on March 31, 2025, their Joint Committee Report on the implementation and functioning of the Securitisation Regulation that feeds into the upcoming European Commission legislative revision of the securitisation regulatory framework.

Our feedback aims to support the European Commission in aligning the Liquidity Coverage Ratio Delegated Regulation with the EUs broader goals of digitalisation, sustainability, and competitiveness. Building on recent policy milestones, our recommendations focus on enhancing financial resilience through the integration of digital tools, interoperable standards, and ESG-linked incentives.