We would like to seek clarification from ESMA on the use of “proxy” data. For instance, many ABCP warehouse transactions contain similar exposures to public non-ABCP transactions, either because they are backed by Master Trusts or the originators have also completed term securitisation issuances. The same warehouse exposures may eventually be used for public non-ABCP transactions. In many cases, the servicer may not provide a specific report for the exposures within a warehouse deal alone, but the performance metrics on a term ABS deal by the same originator would provide a good proxy.