OpenLobby.EU
Explore

Loan Market Association

LMA

The LMA is the trade body for the EMEA syndicated loan market and was founded in December 1996 by banks operating in that market.

Lobbying Activity

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur)

9 Oct 2025 · Verbriefung

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

23 Jul 2025 · Establish contact with regulators, present activity and inquire about regulatory updates.

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

1 Jul 2025 · Financial services policies

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

Please find attached the letter of response from Loan Market Association.
Read full response

Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

I am pleased to attach a copy of the Loan Market Association's response to the call for evidence.
Read full response

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

We welcome the Commissions overarching goal of addressing complexity in, and enhancing the interoperability of, sustainability-related regulation. The EU Taxonomy (EUT) has provided the first consistent sustainable classification system. Although it has been somewhat successful, there have been well-documented usability challenges with the EUT which we believe must be addressed to unlock the full potential of the EUT. We support the Commissions aim of simplification in principle as market participants have experienced administrative burdens in relation to disclosure requirements. It is however also important to ensure that any amendments to the EUT enhance, and do not impede, the interoperability of existing legislation. In particular, the computation of KPIs of financial undertakings will depend on the provision of information from companies and relevant counterparties. We therefore welcome the exclusion of exposures to undertakings other than large undertakings (exceeding the employee threshold in the EU Omnibus Package) from the denominator of relevant KPIs until the Commissions review is finalised. Building on these overarching points, we would like to share the following key considerations: We welcome the Commissions approach to introduce a de minimis threshold with the intention of reducing the administrative burden on financial and non-financial undertakings. However, further clarification around the application to non-bank financial undertakings would be helpful - in particular whether specific guidance is intended to be provided regarding the consideration and analysis of non-material activities of their underlying assets. We strongly recommend that the Green Asset Ratio (GAR) is reviewed and that its inclusion be carefully considered. GAR requires the collection and analysis of granular information and is a significant burden on the resources of financial institutions as well as their counterparties. Evidence also suggests that investors are not requesting, relying on or using GAR in the manner intended. Given the significant administrative burden and questionable value, we therefore recommend that GAR is removed entirely. To the extent that GAR is retained, we recommend a substantive review of the analysis and methodology of GAR calculations and the availability of relevant data and information in order to address well documented limitations and ensure that GAR reporting is functioning as intended. In particular: the denominator and numerator should be carefully considered and aligned (particularly in light of proposed changes of the EU Omnibus Package) in order to ensure symmetry of the ratio; further guidance regarding calculation methodology is required to improve comparability given the variation of business models between banks; and taking into account the aims of GAR reporting, it is not clear why the trading book and fees and commission KPI is included at all and we would recommend the removal (or urgent suspension) of this KPI. We support the Commissions proposals to reduce reported data points financial undertakings compute for their own EUT KPIs. From a compliance perspective, the introduction of the reporting of one activity per row may alleviate costs and administrative burdens. We understand the need to start by reviewing one taxonomy activity (chemicals); however, revising and simplifying the DNSH criteria is important. This has been a source of confusion, and further clarification is required. Market participants are dealing with significant uncertainty at present, with multiple proposals to change legislation. We would like to emphasise the need for careful consideration of the impact of the EU Omnibus Package to ensure that the proposals do not inadvertently add complexity, undermine the legal certainty needed to drive investment decisions and/or lead to an erosion of the quality or ambition of the underlying legislative and economic aims.
Read full response

Response to Savings and Investments Union

7 Mar 2025

Please find the response of the Loan Market Association attached.
Read full response

Response to Enhancing the convergence of insolvency laws

14 Mar 2023

Please find the Loan Market Association's feedback in the attached file.
Read full response

Response to Enhancing the convergence of insolvency laws

9 Dec 2020

Dear Sirs, The Loan Market Association welcomes this opportunity to respond to the Commission's request for feedback on the harmonisation of certain aspects of insolvency law. Please find our response attached. Yours Sincerely, Hannah Brown Loan Market Association
Read full response

Response to Development of secondary markets for non-performing loans

8 Jun 2018

We would like to stress to the Commission that, as discussed with you on 4 May 2018, whilst we recognise the positive legislative intention of the Proposal to encourage development of secondary markets for non-performing loans ("NPLs") and, in particular, welcome the proposed requirement at Article 15(2) for Member States to lift any existing restrictions in national law, such as licensing requirements, which may currently prevent loan transfers being made to non-bank institutions, we are very concerned that the legislation contains a number of measures that would, if adopted in their current form, cause significant uncertainty and disruption to primary and secondary syndicated loan markets. For example: • the mandatory disclosure duty at Article 13(1) would introduce significant changes to well-established, existing market practices based around the "buyer beware" principle; • the proposed reporting requirements in relation to non-bank transferees at Articles 13(2) and 19(1) and the requirement for non-EU non-bank transferees to appoint an EU representative at Article 17 would discourage lenders other than EU banks and their subsidiaries from entering into secondary syndicated loan transactions, thus making it more difficult for EU banks to transfer syndicated NPLs from their balance sheets and decreasing liquidity in secondary syndicated loan markets; • the proposed requirement for non-bank transferees to inform competent authorities before enforcing a loan at Article 18 would make enforcement slower and hamper lender recovery efforts for syndicated lending transactions generally, where there may typically be a mixture of bank and non-bank lenders; and • there may be real practical difficulties with ascertaining whether a participation in a syndicated loan held by a lender other than an EU bank was originated by an EU bank and accordingly whether it would fall within the scope of Title III of the Proposed Directive. In view of the above and the potential disruption that the Proposal would cause to the market, we have suggested the following drafting amendments within the attached letter to carve out syndicated and other wholesale loans from scope: Article 2(6): "Articles 4 to 15(1), 16 to 22 and 34 to 37 of this Directive shall not apply to: (a) syndicated credit agreements; (b) wholesale credit agreements." Article 3(6a): "'syndicated credit agreement' means a credit agreement that provides for, or contemplates, two or more creditors;" Article 3(6b): "'wholesale credit agreement' means a credit agreement concluded between a creditor and a business borrower, other than a business borrower who is a micro, small or medium-sized enterprise within the meaning of Article 2 of the Annex to the Commission Recommendation 2003/361/EC of 6 May 2003;" We consider that limiting application of these requirements to consumer and SME loans, similar to the scope of the new credit servicing regime in Ireland, would be consistent with the objective of the Proposed Directive and the broader Capital Markets Union project to facilitate SME lending. Our response further sets out some additional comments on other aspects of the Proposal, including in relation to the Accelerated Extrajudicial Collateral Enforcement ("AECE") mechanism, which are set out in the Appendix to their letter.
Read full response

Response to Assignment of claims

23 May 2018

This LMA feedback is only concerned with the effect of the Proposal on the assignment of claims in the context of the European secondary loan trading market. The impact of the Proposal on this area of the financial markets is not mentioned in the Proposal or in its Impact Assessments. However, the implications of the Proposal on this market would be significant and the Proposal could, in our view, disrupt a fully functioning and thriving cross-border European secondary loan market by creating new problems for that market, increasing the complexity of those transactions, lengthening settlement times and adding costs. When a participation in a syndicated credit facility is sold by way of assignment by a Lender (assignor), participants in the European secondary loan market would currently only look to the law of the assigned claim (so the governing law of the facility agreement) to ascertain, not only its effects in relation to contractual matters but also in relation to its effects as against third parties. Therefore, participants in the European secondary loan market only look to perfect their assignment in accordance with the laws of the assigned claim. This practise has provided legal certainty and created stability and thereby encouraged cross border investment in this market. It is important to be aware that this practice is facilitated by the fact that assignees in the European secondary loan market are, in the vast majority of cases, provided with a copy of the underlying facility agreement as part of their due diligence processes and so are always able to ascertain the governing law of the facility agreement. Given that only one facility agreement is involved in a secondary loan trade (as opposed to a bundle of facility agreements), this practice makes eminent legal and commercial sense for this market. Accordingly, it is not current market practice for any perfection steps to be carried out in accordance with the laws of the "habitual residence" of the assignor or indeed any other laws other than the law of the assigned claim. Introducing the "habitual residence" of the assignor as the connecting factor for the resolution of proprietary disputes in the context of assignments of claims in the European secondary loan market would be a significant departure from current market practice and the current legal analysis applied by market participants to such assignments. The attached file sets out the potential outcomes of this in more detail. In view of the above and the potential disruption that the Proposal would cause to the European secondary loan market, we would like to suggest that assignments of debt claims against borrowers arising out of syndicated credit facilities and carried out in the European secondary loan market should be granted an exception to the habitual residence rule. The reason for this, as explained above, is that there is already a harmonised approach to the question of the third party effects of cross-border assignments of claims in the secondary loan market based on the governing law of the assigned claim. As with the third party effects of the assignment of cash credited to an account in a credit institution and claims arising from a financial instrument, any exception granted to the secondary loan market should reflect the basis on which that market has generally been operating and the expectations of all participants in that market. Accordingly, the LMA would propose that for assignments of debt claims in the European secondary loan market, the law governing the assigned claim (i.e. the facility agreement) should be the harmonised connecting factor to resolve the third-party effects of such assignments. The manner in which the above could be achieved via amendments and clarifications to the existing proposal is set out in the attached file. The attached also provides more information on the size and nature of the secondary loan market more generally.
Read full response

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

4 May 2018 · Non-performing loans package

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

10 Mar 2017 · Securitisation, CMU