ESMA_QA_1262
28/05/2020
Subject Matter
Consolidated ABCP reporting involving more than one ABCP programme and/or more than one ABCP transaction
    Article 4 (2)(b) and Article 8(2)(b) of the disclosure technical standards states that the reporting entity shall make information available on each ABCP programme which is funding the ABCP transactions. How should these requirements be fulfilled when an ABCP transaction is syndicated and funded via multiple ABCP Programmes, each managed by a different Sponsor? Is there a requirement for each ABCP Programme Sponsor to report on the programme level details of other ABCP Programmes funding the transaction?
    ESMA Answer
    28-05-2020

      [ESMA 33-128-563 Securitisation Q&A, Q&A 5.1.8.a]

      A single consolidated report should be created for each ABCP Programme and all the ABCP Transactions within that Programme. Take the example illustrated in the figure below with two ABCP Programmes (P1 and P2) funding three ABCP transactions T1, T2 and T3. Each Transaction contains two types of underlying exposures Trade Receivables (‘TREC’) and Consumer Loans (‘CONL’).

      Example illustrated with two ABCP Programmes (P1 and P2) funding three ABCP transactions T1, T2 and T3.

      ABCP Programmes “P1” and “P2” are co-funding transaction “T2”. At the same time “P1” is funding the transaction “T1” on a stand-alone basis and P2 is funding the transaction “T3” on a stand-alone basis. In this example, two reports need to be generated, one for P1 and one for P2. The contents of each report is summarised in the table below. For the purpose of this example, this is assumed to be ‘public’ structure. For more information about the disclosure requirements applicable to public and private securitisation see Q&A 1256.

       

      Annex / Section to be completed

       

      Report for P1 includes

      Annex 13 “Investor Report” including

      • ‘Transaction Information Section’ completed for T1 +
      • ‘Transaction Information Section’ completed for T2
       

      Annex 15 “Inside Information Or Significant Event Report” including

      • ‘Transaction Information Section’ completed for T1 +
      • ‘Transaction Information Section’ completed for T2
       

      Annex 11 for Trade Receivables (TREC) in T1

       
       

      Annex 11 for Consumer loans (CONL) in T1

       
       

      Annex 11 for Trade Receivables (TREC) in T2

       
       

      Annex 11 for Consumer loans (CONL) in T2

       
       

      Report for P2 includes

      Annex 13 “Investor Report” including

      • ‘Transaction Information Section’ completed for T2 +
      • ‘Transaction Information Section’ completed for T3
       

      Annex 15 “Inside Information Or Significant Event Report” including

      • ‘Transaction Information Section’ completed for T2 +
      • ‘Transaction Information Section’ completed for T3
       

      Annex 11 for Trade Receivables (TREC) in T2

       
       

      Annex 11 for Consumer loans (CONL) in T2

       
       

      Annex 11 for Trade Receivables (TREC) in T3

       
       

      Annex 11 for Consumer loans (CONL) in T3

       

       

      In each case, the field SEAR3 ‘Number Of Programmes Funding The Transaction’ in Annex 15 should be completed accordingly, in order to identify the other programme identifiers associated with this transaction.

      Status: Answer Published

      Additional Information

      Level 1 Regulation
      Securitisation Regulation (EU) 2017/2402
      Topic
      Securitisation Disclosure Templates