Clifford Chance

ESMA Consults on "Simplified" Disclosure Requirements for Private Securitisations

18 February 2025

The European Securities and Markets Authority ("ESMA") published a consultation paper (the "CP") on 13 February 2025 proposing a new "simplified" disclosure framework for private securitisations which would replace detailed loan-by-loan reporting with more summary, portfolio-level disclosures – a welcome move. However, as an attempt to alleviate the burden of excessive regulation on securitisation, the CP falls short, and it is difficult to understand the thinking behind it in places. The scope of the proposals is so narrowly drawn as to exclude some of the most important use cases for simplified reporting, while also adding reporting requirements that will be new to most market participants.

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