UK Finance and AFME have responded jointly to HMT's Call for Evidence. We noted that the STS (simple, transparent and standardised) regime had not lived up to its designers? and the industry's original expectations and that, perversely, more capital may be required than before the STS regime was introduced.

We proposed moving the bulk of the securitisation regulations  out of primary legalisation to the relevant regulators? handbooks, to increase flexibly and the  ability to respond to market developments. We also encouraged HMT to take into account the international nature of the investors in UK securitisations and a introduce a more proportionate application of the Regulations to private transactions, particularly in relation to the current EU created disclosure templates.