PESH7.498x05.00 AMI 103675EN docx Granularity criterion for ABCP (art. 243 par. 1 (b) CRR-R) ‘Article 243 par, 1 (b) CRR-R requires that positions in ABCP programmes can only quay as STS securt- sation i tthe time of incusion in the securtisation, the aggregate exposure value ofall exposures to a ‘ingle obigr in the poo Goes not exceed! 1% ofthe exposure values ofthe aggregate outstanding expo ‘sure values of the pool of underlying exposures. For the purposes of this calculation, loans or leases to a ‘9roup of connected clients, as referred to in point (39) of Article (1), shal be considered as exposures to. single obligor. ‘We would lke to point out thatthe proposed 1% ceiling forthe exposure toa single obligor at the pro ‘gramme level isnot viable for muit-seller ABCP programmes. the transaction leve! would be no solution either as it would extremely imit the ability to securtise €.9. ‘auto leases with guaranteed residual values. ‘We would, therefore, strongly suggest to mit the scope of the require- ‘ment. As itis neither possible to aggregate obligors over all transactions or to check for groups of con ected clients the 1 9 celing shoulé be applied tothe largest exposure of every transaction pool. For the ‘purpose ofthis calculation, loans or leases to the same abigor in various transactions do not have to be ‘agregated, Article 4 par 39 should not apply. ‘We explicitly welcome that the requirement shal not apply to trade receivables where the credit risk of that is ‘We propose