No, we do not consider the proposed approach as workable in practice. EBA's recommendations could damage proven financing structures in the real economy. Our main concern is that the proposed definition of shadow banking entities is too extensive and overshoots the actual goal to limit increased systemic risks.
Concrete, we propose to extend the scope of excluded enterprises to financial services companies of industrial groups the main purpose of which is to render financial services to the companies of this group (in-house financial services). Furthermore, we propose to extend the scope of excluded enterprises as follows:
• Special purpose vehicles from simple, transparent and standardised securitisations (asset backed securities and asset backed commercial papers)
• Special purpose vehicles from securitisations with asset backed securities that are not exposed to material funding risk by maturity mismatch between the securitised underlying assets financing real goods and the issued asset backed securities (real economy securitisation without material funding risks). (see also attached comments).