The members of the European Association of Co-operative Banks (EACB) have followed with interest the Securitisation file as its members consider that a functioning securitisation market – supplementing bank loans as a main financing instrument – is essential to support growth, and for providing sufficient credit to companies, particularly to small and medium-sized enterprises (SMEs).
Securitisation is indeed a very important element, also from our perspective as co-operative banks, as it fills a "middle ground" between direct bank lending and pure capital markets funding. That is, allowing smaller banks (for instance within co-operative networks) to finance their lending to SMEs and individuals through an access to the capital markets that makes it possible to generate high-rated securities backed by such kind of retail lending. It also allows to better diversify risks and unlock capital in order to improve local lenders' ability to continue financing and boosting economic growth in their regions.
In this context the members of EACB welcomes the Commission’s proposal to create a comprehensive securitisation framework as an important step in the context of the Capital Markets Union project (CMU). However, we fear that the final outcome might not be appropriate to establish a strong European Securitisation Market.
When it comes to the homogeneity criteria, we would like to share the following targeted considerations:
The EACB members agree with the basic approach of the draft RTS regarding homogeneity. Having said that, we suggest that banks should have more flexibility to select risk factors to be considered for each asset category or to define homogeneous sub-portfolios within single transactions.