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PGIM

PGIM is a global asset management company.

Lobbying Activity

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

13 Jan 2026 · Meeting on Securitisation

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

20 Nov 2025 · Securitisation

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Nov 2025 · Sustainable Finance: SFDR, Benchmarks, Omnibus

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Nov 2025 · SFDR

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

14 Oct 2025 · Securitisation

Meeting with Reinhard Felke (Director Economic and Financial Affairs)

13 Oct 2025 · Informal exchange of views on the European economy, growth and competitiveness, and developments in fixed income markets.

Meeting with Eero Heinäluoma (Member of the European Parliament)

3 Sept 2025 · Securitization market resilience & Savings and Investments Union

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

13 May 2025 · SIU & Securatisation

Response to Review of the Securitisation Framework

18 Mar 2025

At PGIM, we welcome the European Commissions focus on the securitisation markets in the broader context of the Savings & Investments Union and the critical need for economic growth and European competitiveness. We manage over 130B of securitised assets for European and non-European clients which we believe gives us a unique insight into the impact of regulations . Alongside this short response, we submit a longer PGIM white paper entitled Reviving European Securitisation: Translating Ambition into Reality. Europes securitisation market has shrunk to 17% of the size of the U.S. market (from 85% pre-GFC). This is unfortunate given that securitisation could be playing a much bigger role in meeting the funding needs of critical sectors like housing, corporates, SMEs and renewables. Securitisation provides important opportunities for pension funds, insurance companies and even retail investors to diversify investment risk while earning stable returns. Inertia in Europe is largely driven by an over-regulated market. Regulation was crafted with good intentions but has resulted in unintended consequences. Europes rules are applied regulation in the form of the EU Securitisation Regulation (EUSR) with a heavier, more prescriptive footprint than other jurisdictions. Solutions are feasible, assuming we have the political will, boldness and high ambition. There is an opportunity to bring market-enabling reform as outlined in the Draghi Report. A number of changes and recalibrations to the EUSR are needed: Simplify Due Diligence Requirements The EUSRs heavy and prescriptive due diligence obligations add unnecessary operational burden for investors, particularly smaller institutions. Policymakers should consider introducing a principles-based investor due diligence framework which would allow the end-investor to judge whether a given securitisation meets their needs. Or better yet, as in most other jurisdictions, remove investor due diligence entirely, taking comfort that securitisation issuers are well-regulated and that todays stringent underwriting is robust. Simplify Reporting Standards Granular EUSR reporting requirements create excessive issuance hurdles without adding meaningful value for investors. Reducing burdens will incentivise more issuance and investment while greatly reducing costs and frictions. Recalibrate Insurance Capital Requirements Current Solvency II capital charges for securitised products are disproportionately high compared to their risk profiles. Insurance capital requirements in Europe are higher, sometimes astronomically higher, than in jurisdictions with more developed markets; this severely dampens demand. Capital requirements should be risk-sensitive and based on evidence. Facilitate greater UCITS Investment EU regulators treat securitisation investments with extreme caution in the context of UCITS supervision, only allowing limited investment in some securitisations. Supervisors should take comfort in the nearly two decades of sound performance of securitisation, especially in the most senior, investment grade tranches (i.e. AAA and AA rated). Expand EU Investors Access to Global Markets The EUSR restricts investors to securitised assets that adhere to EU standards, leaving them locked out of 75% of the global securitisation market. This puts European investors and financial products at a significant disadvantage to investors and products in other global financial centres. Individually, these changes may have limited impact on the growth of the EU securitisation market, but together, they have the potential to be transformative. If we approach this work with equal amounts of thought and political ambition, these changes will deliver big outcomes for borrowers and investors. Now is the time for bold reforms to unlock Europes securitisation potential and ensure its place at the forefront of global capital markets.
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Response to Savings and Investments Union

6 Mar 2025

PGIM welcomes the European Commissions (EC) call for evidence as a further step in the continuous effort towards promoting and building a cross-border Capital Markets Union and accelerating this into a Savings and Investments Union (SIU). The current fragmented financial landscape and complex regulatory framework are not fit for purpose to meet the urgent financing needs for Europe. If the EU continues its current trajectory of weak investment, its productive capacity will continue to erode, falling further and further behind international competitors. The opportunity for bold reform is now. The SIU agenda is not a nice to have but an essential ingredient to ensure the sustainable future of Europe. PGIM highlights the following four areas as essential for a successful and sustainable SIU. Advancing Capital Markets Unlocking unused potential of alternative access points to capital can help the EU finance its growth ambitions in all areas, including competitiveness, security, and the Clean Industrial Deal. Access points to capital include: Securitisation markets to facilitate credit expansion, allow European financial intermediaries to increase and diversify their funding sources, enhancing portfolios of retail and institutional investors. Private credit market to support innovative businesses in scaling up; the diffuse localised nature of private credit will help further develop capital markets across the Union. Supporting global asset managers as long-term partners of European enterprises, lending expertise, access to international markets and support in scaling-up. Reducing Cross-Border Barriers The lack of financial integration acts as a dragging anchor on the EU. Reductions in intra-EU barriers are needed to complete the single market and help the Union unlock its capital potential. Only through integration can the EU enhance its self-sufficiency when it comes to long-term capital. Barriers remaining: Direct lending passport for loan-originating AIFs in the AIFMD 2 framework. Use important role of EC as a stable voice to define EU-wide maximum standards instead of gold-plating per country. Use best-practice examples. Simplifying Regulation Simplification should not mean lowering standards for the sake of it but acknowledging that some standards have been raised too high, thus stifling market potential. For each new piece of regulation, the question whether it will deliver growth, must be answerable in the affirmative to increase competitiveness. Areas that urgently need simplification include: Overregulation has diminished the securitisation market, now 17% of the size of the US market (down from 85% pre-GFC), due to duplicative, costly, and burdensome due diligence requirement, transparency rules, and excessive capital requirements. Focus on enforcement, existing regulation can perform well if enforced as intended, EC needs to prioritise regulations that grow the market, ensure proper enforcement of regulations already in place. Not applying Level 1 frameworks before Level 2 rules are finalised. Robust cost-benefit analysis and consumer testing where appropriate ensures long-term successful regulation. Improving Retail Investment The EU is home to 33 trillion Euros in private savings, predominantly held in currency and deposits. Consumers are less likely than in other markets to invest their savings long-term. Aspects hindering retail investment include: Over-complicated product disclosures focusing predominantly on potential risks and costs discouraging investments. Offering best possible products, cheaper does not mean better, need true value-for-money approach. Cost benchmarks hurt retail investors if they limit choice, competition, and innovation. Infrastructure for ease of access: introduce tax-advantaged investment account, use best-practice examples from EU and third countries (e.g. ISK in Sweden, 401(k) in US), promote auto-enrolment, pensions dashboards, and tax incentives.
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

5 Mar 2025 · Exchange on Securitisation

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Jan 2025 · Discussion on Sustainable Finance Disclosure Regulation Seven-Categories Proposal

Meeting with Fernando Navarrete Rojas (Member of the European Parliament)

12 Sept 2024 · Eurofi

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

19 Jun 2024 · Capital Markets Union