SFA Response to FCA CP26/6 and PRA CP2/26 on UK Securitisation Framework Reform

Sep 13, 2026

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18 May 2026 responses submitted by the Structured Finance Association to the Financial Conduct Authority and the Prudential Regulation Authority consultations on reforming the UK securitisation framework. The submission endorses proposals designed to ensure institutional investors receive sufficient, decision-relevant information, while preserving a sensible balance between investor understanding and flexibility for sophisticated professional investors. It also supports removing specific prescriptive disclosure tables to allow market participants to determine information needs, format and frequency, and discusses requirements to form an internal view on the robustness of credit granting processes.

LanguageEnglish

CategoryLetters

FormatPDF

Pages20

Reading Time7 min

AccessFree to download

Consultation Questions and Responses

Question 1

Question 2

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18 May 2026 Securitisation Policy Financial Conduct Authority 12 Endeavour Square London E20 1JN Securitisation Policy Prudential Regulation Authority 20 Moorgate London EC2R 6DA Re: FCA Consultation Paper CP26/6 – Rules for reforming the UK Securitisation Framework and PRA Consultation Paper CP2/26 – Reforms to securitisation requirements (the "CPs") Ladies and Gentlemen: The Structured Finance Association would like to thank the Financial Conduct Authority (the "FCA") and the Prudential Regulation Authority ("PRA") for the opportunity to contribute to the debate on the important issue of the reform of the UK Securitisation Framework. We firmly believe that a responsible and proportionate securitisation framework is a key building block to ensuring the growth of a thriving, but sustainable, securitisation market to support the UK economy's funding needs. We further believe that the CPs are an important step on the journey toward that goal. The Structured Finance Association 1 ("SFA") represents over 360 members from all sectors ofthesecuritisation market, and our core mission is to support a robust and liquid securitisation market. SFA provides an inclusive network for securitisation professionals to collaborate and, as industry leaders, drive necessary changes, be advocates for the securitisation community, share best practices and innovative ideas, and educate industry members through conferences and other programs. In balancing the interests of our diverse membership, SFA values consistency and clarity across applicable regulations. Below we have provided our responses to the questions the FCA poses in its CP and indicated the corresponding proposals ofthe PRA CP to which our answers are also responsive. 1 SFA is a member-based, trade industry advocacy group focused on improving and strengthening the broader structured finance and securitisation market. SFA provides an inclusive network for securitisation professionals to collaborate and, as industry leaders, to drive necessary changes, to be advocates for the securitisation community, to share best practices and innovative ideas and to educate industry members through conferences and other programs. While our members often have conflicting views and interests, our governance structure requires consensus from all stakeholders. Further information can be found [at](at www.structuredfinance.org)[ ](at www.structuredfinance.org)[www.structuredfinance.org](at www.structuredfinance.org). | Consultation question | Response | | --- | --- | | Question 1: Do you agree with our proposals and their focus on ensuring that institutional investors obtain sufficient information from the manufacturer of thesecuritisation? Please elaborate
on your response. PRA Proposal 1 | Yes. Most jurisdictions outside Europe with significant securitisation markets do not have securitisation-specific due diligence rules. The more common model is for disclosure to be regulated. On the buy side, the various categories of regulated institutional investor are subject to sectoral rules of conduct designed to support a more general principle that institutional investors are required to act as responsible fiduciaries of their stakeholders'funds (e.g. around due diligence, diversification and reporting to stakeholders) . These sectoral rules do not generally contain specific diligence rules affecting particular asset classes.
While the CPs' proposals do not go quite so far as to eliminate the concept of securitisation-specific due diligence rules, we believe that the proposals strike a sensible balance between, on the one hand, the valid regulatory interest in ensuring investors properly understand what they are invested in (especially where they are fiduciaries investing on behalf of their stakeholders), and on the other hand, the need to ensure that sophisticated professional investors have the flexibility required to be able to execute investment strategies and produce the

FAQs

What is the Structured Finance Association’s overall position on the FCA and PRA consultation proposals?

The submission supports reforms intended to ensure institutional investors obtain sufficient information and that proposals strike a balanced approach between regulatory interest and investor flexibility.

Why does SFA agree with the proposal to ensure institutional investors receive sufficient information from manufacturers?

SFA agrees that investors should properly understand what they are investing in so they can make responsible, well-informed decisions, while recognizing information needs can vary by investor, transaction, and jurisdiction.

What does SFA think about removing the prescriptive table at SECN 4.2.1 R (1)(e)?

SFA welcomes the additional flexibility created by removing the table and related guidance, emphasizing that the securitisation market is a wholesale market where investors can decide what information they need and how often.

Sep 13, 2026

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