On 17 September 2025, the LMA published its recommendations on further improving the EU securitisation framework following the European Commission's recent proposals (SR Proposals). 

Securitisation has an enormous potential to boost EU funding by attracting capital globally. But without a clear, proportionate regulatory framework, investor confidence - and thus Europe’s competitiveness - remains at risk.

In our position paper accompanied by detailed technical annex, we put forward key recommendations across three areas to help advocate for a more proportionate and ambitious regulatory framework - (i) building market confidence; (ii) removing investor barriers; and (iii) ensuring proportionate capital and liquidity requirements.

On 15 September 2025, together with Bank Policy Institute (BPI), the Swiss Finance Council, UK Finance, the UK Association of Foreign Banks (AFB), the Bankers Association for Finance and Trade (BAFT), and the Japanese Bankers Association (JBA), the LMA has published a position paper on EU Member States’ implementation of the branch requirement under CRDVI. This paper is intended to:

• highlight the approach that we believe best aligns national transposition with the policy intent behind CRD VI; and
• identify areas where certain transposition proposals or interpretations to date appear to have inadvertently diverged from the Level 1 text or policy intent.

On 8 August 2025, the European Banking Authority published a Q&A response (prepared by the European Commission) on the use of conditional sale agreements as a means for an entity to qualify as an originator.

We are aware of the widespread use of conditional sale agreements in CLO structures and the impact that this response has had in the CLO market, particularly for those deals that have closed or priced but not yet closed.  We have contacted the European Commission, the European Banking Authority and other supervisory authorities to seek further clarification on the application of the response to these transactions.