ISLA response to Central Bank of Ireland’s
consultation CP77: Consultation on publication of UCITS rulebook.
Please find attached here ISLA's response to the Central Bank of Ireland's consultation paper concerning amendments to the UCITS Rulebook for you information.
The response was prepared following discussions with the UCITS working group and I would like to thank them for their help in this matter
ESMA has now published it’s revision to the Guidelines following consultation. We will produce a fuller analysis but ESMA has listened to arguments from us and other market associations and extended the new collateral diversification requirements to all UCITS and not just money market funds as proposed. Under the new guidelines, UCITS that receive collateral from any one issuer of more than 20% of its NAV are required to make additional disclosures, and ESMA further requires that collateral must be diversified across at least 6 different issues.
The new Guidelines can be found here.
ISLA responds to ESMA’s consultation document “Revision of the provisions on diversification of collateral in ESMA’s guidelines on ETFs and other UCITS”.
ISLA has submitted a response to ESMA’s consultation on proposals to amend the collateral diversification rules contained in its guidelines for ETFs and other UCITS. The current guidelines require that no more than 20% of the NAV of a UCITS may be held in collateral from any one issuer. In the consultation ESMA consider allowing a derogation from this provision for government issued collateral in certain circumstances. The proposal is that this derogation should be limited to money market fund UCITS only to allow them to use higher volumes of reverse repo against a single government issuer.
ISLA argues that whilst it supports the proposal, the derogation should be available to all UCITS (not just MMFs). A copy of ISLA’s response can be found here.
Draft EU regulation on reporting and transparency of SFTs – Clifford Chance Briefing
Further to our announcement last month you may be interested to read a briefing note from Clifford Chance on this development. The briefing note can be accessed here.