News in STS securitisations: homogeneity

2023-03-22T12:28:00
Spain
EBA publishes final report on the draft RTS regarding homogeneity requirements
News in STS securitisations: homogeneity
March 22, 2023

On 14 February 2023, the European Banking Authority (EBA) published a Final Report on a draft regulatory technical standards (RTS) regarding the homogeneity requirements established under Articles 20(14), 24(21) and 26b(13) of the Securitisation Regulation.

The new RTS will be implemented as an amendment to Delegated Regulation (EU) 2019/1851 upon endorsement of the European Commission and the scrutiny by the European Parliament and the Council (the "Homogeneity RTS Amendment").

Key aspects

This Homogeneity RTS Amendment updates the following:

  • The asset type of credit facilities for individuals will also cover enterprises (jointly) but only if the originator applies the same credit risk assessment approach.
  • The same approach is implemented to the homogeneity factors available for asset type of auto loans and leases.
  • The similar-servicing requirement will also consider the servicing at the originator level in order to accommodate this requirement to on-balance-sheet transactions.
  • The homogeneity RTS will acknowledge that homogeneity factors are applied “where applicable”, because some assets have no homogeneity factors.

Homogeneity framework

For exposures to be deemed homogeneous under the Securitisation Regulation, they must meet four requirements:

  • Asset type: corresponding to (only) one asset type.
  • Underwriting:  similar approaches for assessing credit risk.
  • Servicing: similar procedures (see below).
  • Homogeneity factors: one or more to be applied in connection with the asset type (see below).

Homogeneity factors

Homogeneity factors are available in connection with some asset types as follows:

Amendments to the homogeneity regime

The Homogeneity RTS Amendment will include these main updates:

  • The asset type “credit facilities provided to individuals for personal, family or household consumption purposes” will now extend to credit facilities provided to enterprises (where the originator applies the same credit risk assessment approach as for individuals not covered under other asset types).

Article 1 (a):

(iii) credit facilities provided to individuals for personal, family or household consumption purposes and credit facilities provided to enterprises where the originator applies the same credit risk assessment approach as for individuals not covered under points (i), (ii) and (iv) to (viii);


  • The same approach applies to one of the homogeneity factors of the asset class related to auto loans/leases. In particular, the homogeneity factor of “type of obligor” initially applied to “individual” will now extend to enterprises (again, where the originator applies the same approach for assessing the credit risk).

Article 1 (a):

(iii) credit facilities provided to individuals for personal, family or household consumption purposes and credit facilities provided to enterprises where the originator applies the same credit risk assessment approach as for individuals not covered under points (i), (ii) and (iv) to (viii);


  • The similar-servicing requirement will also consider the servicing at the originator level to accommodate this requirement to synthetic transactions.

Article 1 (d):

(c) they are serviced in accordance with similar procedures for monitoring, collecting and administering cash receivables of the originator, or on the asset side of the SSPE;


  • Since some asset types have no homogeneity factors, a clarification is added to the homogeneity factor application requirement.

Article 1 (d):

(d) one or more of the homogeneity factors are applied in accordance with Article 2, where applicable;

March 22, 2023