Securitisation Regulation Questionnaire 2018

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* 1. Please enter your contact details

Name

Firm name

Email address

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* 2. Which of the following best describes your firm?

An asset manager that is an EU AIFM/MiFID investment firm

An asset manager that is a non-EU AIFM

A law firm

A service provider to asset managers

Other (please specify)

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* 3. There is uncertainty whether the definition of “institutional investor” could be interpreted as applying to non-EU AIFMs marketing AIFs in the EU. Considering this uncertainty, are you or your clients:

Taking steps to cease marketing in the EU

Taking steps to comply with the risk retention/due diligence requirements under the Securitisation Regulation

Taking the view that the Regulation is not intended to apply to non-EU AIFMs and so carrying on as normal

N/A: we are not a non-EU AIFM marketing AIFs into the EU

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* 4. Do you or your clients currently use a dual SPV structure for your warehouse?

Yes

No

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* 5. Do you or your clients anticipate using a dual SPV structure for your warehouse before the Securitisation Regulation comes into force in 2019?

Yes

No

We are considering doing so

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* 6. Do you or your clients currently use a non-EU collateral manager for warehouse transactions?

Yes

No

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* 7. Are you or your clients considering setting up a non-EU collateral manager for warehouse transactions in response to the Securitisation Regulation?

Yes

No

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* 8. Have you considered whether a static CLO could be structured within the STS requirements?

Yes, and we think that this is possible

Yes, but we do not think this is possible

No, we have not considered this

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* 9. What would you describe as the three key challenges for your firm’s/your client’s implementation of the Securitisation Regulation:

Uncertainty over the scope of the requirements

Uncertainty over the substance of the requirements

Insufficient time to comply

Availability of internal resource

Availability of expertise from third party service providers

Other (please specify)

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* 10. If you have any additional comments on your firm’s/your clients’ implementation of the Securitisation Regulation, please include these in the comment box below: