PCS filed its response to the FSB's request for feedback on the success or otherwise of the G20 reforms of the rules surrounding securitisation.
Although the FSB is a body with a global remit, in line with our social purpose and our area of expertise, PCS' response deals with the impact of securitisation regulations in Europe, including both the European Union and the United Kingdom. In view of the very short time provided by the FSB for comments - a mere three weeks - our piece is short and provides a high-level view of the impact of the current regulations together with broad conclusions as to both why the current regulatory framework does not appropriately reflect the actual risk profile of European securitisations (especially STS) and what could be done to remedy this state of affairs.
PCS' argument is not that we should roll-back the reforms that emerged from the G20 work plan. Many, even most, were necessary and beneficial. On the contrary - and as we have written elsewhere - there is a need to complete those reforms so as to reflect the legislative removal of agency risk via the Securitisation Regulation and the creation of the STS standard.
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