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True Sale International GmbH

TSI

Förderung von Qualität im deutschen Verbriefungsmarkt durch - Bereitstellung einer Qualitätsmarke, die auf hohe Transparenz, Ausschluss von Originate to Distribute, hohe Kreditvergabestandards und bestimmten Anforderungen an den Wertpapierprospekt aufbaut - Bereitstellung von Emissionsgesellschaften nach deutschem Recht mit einem hohen, normierten Qualitätsstandard - Förderung des Informationsstands und der Qualifikation der Marktteilnehmer durch Workshops, Trainings und Konferenzen - Vertretung des Themas gegenüber der interessierten Öffentlichkeit sowie Politik und Gesetztgebung

Lobbying Activity

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur) and Bundesverband deutscher Banken e.V. and KfW Bankengruppe

23 Sept 2025 · Verbriefung

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

15 Jul 2025

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. We agree when the European Commission states: Now that appropriate safeguards have been firmly embedded in the markets organisation and securitisation is gaining back investors trust, a better balance between safeguards and growth opportunities - both for investments and issuance - needs to be found. In this context, we believe that there is not just one single silver bullet. Rather, a whole set of measures is needed to remove the existing obstacles. The regulations on the recognition of securitisations in banks' Liquidity Coverage Ratio (LCR) in our opinion is one of the building blocks in this respect. As in our comments on the targeted consultation on the functioning of the EU securitisation framework TSI and GBIC still consider it justified to improve the recognition of securitisations under LCR. Pursuant to current CRR provisions and the delegated regulation on LCR (Articles 12 and 13), specific senior tranches in STS securitisations can qualify as level 2B liquid assets. From our point of view the ability of securitisations to qualify in the LCR should be amended - without further conditions to Senior STS securitisations (HQLA Level 2A) and Senior non-STS securitisations (HQLA Level 2B). The EU Commission's proposal contains some changes that are necessary and helpful: - Realigning minimum credit quality steps (CQS1 to CQS4 or AAA to AA-) and extending it to CQS5 to CQS7 (A+ to A-) - with a 50% haircut, - Removing the EU-specific requirement for securitisations eligibility to have a remaining weighted average life (WAL) of five years and - Alignment of homogeneity requirements with the corresponding STS requirements of the Securitisation Regulation (SECR) and therefore extending the scope of eligible asset classes. However, a clarification should be added that ABCP positions are now LCR eligible. In addition, a reduction of the haircut from 25% to 15% in CQS1 to CQS4 is proposed for securitisations that the Commission considers to be resilient. For this classification, further criteria (e.g. specific attachment point) must be met. We reject the introduction of a new regulatory securitisation category resilient with additional requirements - as currently envisaged - for the following reasons: - A new layer of complexity is introduced. - New entry barriers are created for market participants and potential market participants. - Some of the specific requirements for resilient securitisations in the proposed amendments to the Capital Requirement Regulation (CRR) are inappropriate and may create false incentives. For example, the specification of a minimum attachment points favours riskier transactions, as they were above the minimum requirement anyway. Low risk portfolios as for example Auto ABS or Trade Receivables securitisations would be forced to have thicker first loss positions. - Last but not least, we do not expect the definition of resilient transactions to cover a sufficiently large part of the market to have a meaningful positive impact. Consequently, we are concerned about further segregation within the securitisation market. Therefore, the LCR should only be linked to the resilient category after it has been adjusted under the CRR. The recalibration of the LCR constitutes a necessary but not sufficient measure. Its intended effectiveness will only be achieved if the other components of the regulatory framework particularly the prudential treatment of banks as investors, the applicable capital requirements and the due diligence and reporting obligations are subject to appropriate and coherent reform. As a result, a final assessment of the draft Delegated Regulation amending the LCR is only possible in conjunction with the amendments to the CRR.
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Response to Review of the Securitisation Framework

26 Mar 2025

Introductory Remarks: BdB and TSI appreciate the opportunity to answer to this Call for Evidence. Having responded to the Targeted Consultation, we emphasize here on the key aspects essential to achieving the defined objectives. European Competitiveness, Financing the Transition and Securitisation: Facing a significant investment gap, strengthening European competitiveness is of utmost importance efficient capital allocation alongside private and public equity markets plays a key role. In this context, securitisation is one important instrument to manage risks and providing the real economy with necessary debt financing. However, reservations in the public sphere, overregulation in the aftermath of GFC and sluggish progress regarding the European Capital Markets Union have undermined the revival of securitisation. Regulatory improvements are long overdue to support a robust EU securitisation framework without creating new risks. Lessons learned from the Global Financial Crisis: The GFC exposed severe flaws in the regulation of securitisation: poor asset quality was combined with excessive leverage by different means of securitisation. This has prompted huge losses at global scale. At the same time, however, data clearly prove that traditional and synthetic balance sheet securitisations in established asset classes in Europe have performed very well pre, during and after the GFC. As immediate reaction, international standard setters and European legislators rightly prohibited synthetic arbitrage and re-securitisation, and imposed risk retention and due diligence rules in 2010. However, the framework implemented in 2019 also contains requirements that do not correspond to the risk profile of European securitisations, lead to overcapitalisation and generates a high level of bureaucracy. Banks take on a wide range of roles in the securitisation market: The upcoming legislative proposal must recognise that banks take on a wide range of functions in the securitisation process and play a central role in the different market segments: 1. Synthetic balance sheet securitisation (ca. EUR 150bn transaction volume p.a.): Main asset classes are corporate and project finance loans with over 80%. Banks achieve partial risk transfer and regulatory capital reduction, leading to new lending capacity for the real economy. In this segment, banks always retain the low-risk senior tranche. 2. Public ABS (ca. EUR 250bn issuance p.a.): Main asset classes comprise auto loans and leases, consumer and equipment leases, residential mortgages, SME and CLOs. Banks make up for ca. 30-50% of investors in low-risk senior tranches. While asset managers and insurers should generally play a greater role, banks continued involvement for a liquid securitisation market is essential. 3. ABCP and private non-ABCP (ca. EUR 230bn outstanding volume): Main asset classes are trade receivables (working capital finance to corporates) with over 60%, and auto, consumer, leasing and SME (25%). Here, banks always fully finance the low-risk senior tranches. The list clearly shows that there can only be a kick-off effect for the securitisation market if the transfer, investments and refinancing by banks become more economical at the same time. This will be the case for banks if the Commission's proposals include significant adjustments to capital requirements in addition to procedural simplifications. No Silver Bullet Key Conclusions: In order to achieve a significant effect for the securitisation market, a comprehensive package is required. This package needs to take into account the aforementioned roles of banks in securitisations. The Commission's proposal should therefore be bold and tackle all of the adjusting screws. A bundle of measures is the key to reducing the burden on existing and new market participants. The comprehensive procedural requirements for securitisations also justify an adjustment to the overcapitalisation of securitisations.
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Meeting with Markus Ferber (Member of the European Parliament)

3 Dec 2024 · Securitisation Review

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

9 Apr 2019 · Securitisation, CMU

Response to Revised calibrations for securitisation investments by insurance and reinsurance undertakings under Solvency II

8 May 2018

The comments uploaded today with the file name "20180427_Kommentierung Solvency II_STS_englisch" are to be replaced by the attached comments "20180508_Kommentierung Solvency II_STS_englisch". Please delete the outdated file. Many Thanks!!!
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