Question ID 2021_6201 (posing a similar question) was rejected, on the grounds of the issue being explained or addressed in Article 224(6) - on the contrary, article 224(6) refers only to "For unrated debt securities issued by institutions or investment firms and satisfying the eligibility criteria in Article 197(4)," and Article 197(4) refers only to "An institution may use debt securities that are issued by other institutions or investment firms"; this in not generally the case with Securitisation position, which are commonly issued by SPV, which would be classified as Corporate Issuer. 

With the implementation of the new Securitisation Regulations on 1 January 2019, the definition of eligible collateral (Article 197(1)(h)) expanded to include both ECAI rated securitisation tranches and unrated tranches, so long as RWA is at or below 100% (using Sec-ERBA or Sec-SA). Prior to 2019, only ECAI rated securitisations with CQS 1-3 qualified as eligible collateral. While the scope of eligible collateral was amended, the FCCM supervisory volatility haircuts (Table 1 in Article 224) have not been updated to include haircuts that correspond to the newly eligible unrated securitisations that under Sec-SA attract a risk weight of 100% of lower. 

Furthermore, the amended and expanded securitisation CQS ratings, which use a scale of 1-18, have not been translated into Table 1 of Article 224, which continues to refer to CQS 1-4.