One of my clients is potentially subject to private securitisation reporting requirements (https://www.fca.org.uk/publication/handbook/fca-pra-reporting-of-private-securitisations-direction.pdf) and therefore would appreciate it if anyone is able to clarify few questions (see below) that I have on this matter.
In terms of what I’ve been able to find so far for the UK FCA requirements:
I’ve got a copy of Annex A and B in the FCA Notification template to be sent to the following address: private.securitisation@fca.org.uk .
Question 1: In terms of timing, should we wait to send this at “the closing date of the most recent issuance, or the most recent date of creation of securitisation positions” given this is a required data field in SECPR16? i.e. only once we’re ‘live’
We are also required to submit EU reporting under ESMA – templates are Annex 4 and 12 – covering both the underlying exposure level as well as portfolio level.
In terms of the UK reporting requirements, for the underlying exposure level reporting, I cannot find specific FCA templates. It seems they are largely still utilising the ESMA templates however I found a doc titled “FCA 2020 80”: –
Question 2: Are these the only differences between the EU and UK reporting at underlying exposure level and are these differences now in force?
Question 3: I couldn’t see any suggested differences on the Annex 12 template between EU and UK – is that correct?
Question 4: Do we need to submit these templates directly, or, similar to EU requirements, make them available on a website?
Question 5: Is there anything else we need to submit to the FCA for private securitisations?
Happy to discuss further if needed.
Any help would be much appreciated.
