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Structured Finance Association Releases Policy Position Paper on Proposed Amendments to the European Securitization Framework

Published on September 15, 2025

WASHINGTON, September 15, 2025 – The Structured Finance Association (SFA), a leading trade association representing the structured finance and securitization industry, today released a policy position paper on the European Commission’s proposed amendments to the European Securitization Framework.

In the paperSFA welcomes the reforms as a meaningful step toward simplifying the securitization regime, reducing disproportionate regulatory burdens, and fostering more efficient and resilient capital markets in Europe.

“Securitization plays a vital role in financing economies, enabling citizens and businessesto reap the benefits of safe investments and increased access to responsible credit,” said Michael Bright, CEO, Structured Finance Association. “We commend the European Commission for recognizing the need to reduce unnecessary complexity and to better align regulatory requirements with market realities. Our members believe these reforms, with targeted adjustments, can help revitalize the European securitization market and make it more globally competitive.”

The policy position paper highlights the following key recommendations:

  • The simplification of due diligence requirements proposed is helpful, but does not go far enough.
  • Simplification of transparency requirements is a key positive step that SFA strongly supports.
  • SFA recommends narrowing the definition of “public securitization” so that it captures only transactions intended to be widely distributed and strengthening confidentiality safeguards for private securitizations so parties can disclose information to public authorities and to each other without fear of wider dissemination of sensitive information.
  • SFA supports the removal in respect of securitizations of the 10% limit on UCITS investments in the debt securities of a single issuer.
  • The moves to make the bank prudential regime for securitization more proportionate are welcome. However, SFA recommends certain adjustments in order to realize the potential of the European markets.
  • SFA broadly supports the adjustments to Solvency 2.

About the Structured Finance Association:

With more than 370 member institutions comprised of accounting firms, broker/dealers, diversified financial intermediaries, investors, issuers, IT vendors, law firms, mortgage insurers, other small financial institutions, rating agencies, servicers, and trustees, SFA is the leading voice for the global securitization industry.

SFA is focused on helping grow the real economy and improving the lives of individuals, families, businesses; helping make credit more affordable and available to people who need it to finance some of life’s biggest goals — education, car purchases, starting a business, buying a home — or reduce their debt through consolidation loans; safeguarding essential protections for consumers and the financial system; facilitating valuable dialogue among the financial services market, its practitioners, policymakers and the broader public; and recognizing that all finance entails risk, but it should not involve recklessness.

For inquiries, please contact:

Walt Cronkite, Director of Communications, SFA

Walt.Cronkite@StructuredFinance.org