It is not a widely known fact that some European Union laws can be adopted by the other three countries of the European Economic Area - namely Norway, Iceland and Lichtenstein - in such a way that, once adopted those countries are considered to be fully part of the EU for the purposes of the subject matter of those laws. Even less known, we suspect, is that the EU Securitisation Regulation is such a law. This week, five years after coming into force in the EU, the Securitisation Regulation (and its later 2021 amendment) was formally adopted by the EEA. This is not quite the end of the story since this adoption must now be itself voted into local law in the three non-EU countries of the EEA. But once this is done, securitisations from Norway, Iceland and Lichtenstein will be considered EU securitisations. They will have access to the STS status - including for synthetic SRT transactions - and the commensurate capital requirement modifiers. EU investors will be able to treat those STS securitisations as EU STS transactions. Pace to our friends in Reykjavik and Vaduz, but - considering the tiny size of the other two markets - all eyes are on Oslo. It is widely believed that the Norwegian government will pass the necessary legislative acts sometime in the autumn so that the all package of changes will come into force on January 1st 2025.
Created by Proformat
