[ESMA 33-128-563 Securitisation Q&A, Q&A 5.13.2]

It is first recalled that recital (13) of the disclosure regulatory technical standards includes the following text: “The set of ‘No data’ options from ND1 to ND4 is meant to signal legitimate cases of information not being available and under no circumstance should constitute an exemption from reporting requirements. Furthermore, use of these options in reporting underlying exposures information in a given securitisation is expected to be limited and, where present, to converge quickly towards reporting of the relevant information.”

Furthermore, Article 7 of the Securitisation Regulation stipulates that one entity among the originator, sponsor, and SSPE shall be responsible for fulfilling the disclosure requirements. The fact that a sponsor may not have information available does not necessarily imply that the ‘No Data’ options can be used, if such information can easily be provided to the sponsor from other entities active in the securitisations, such as the originator(s) and/or SSPE. See also Q&As 1283, 1286, 1288, 1290 and 1291.