Changes to the Securitisation System Reporting Guidance
Alignment with Economic and Financial Statistics (EFS) definitions
The RBA has updated the RMBS reporting guidance to align the definition of two loan-level fields with those that will be implemented in the modernised Economic and Financial Statistics (EFS) collection. As flagged in the announcement in October 2017, the two fields affected by the update are:
- Property purpose. This field should be reported according to the usage of the funds that have been borrowed, not the usage of the property posted as the main security of the loan. Where there is doubt or ambiguity over whether a loan is for an owner-occupied or investment property, information providers (IPs) should assume that the property purpose is for an investment.
- First home buyer flag. IPs may no longer rely on first home owner grant data to populate this field (i.e. investor first home buyers and others not eligible for first home owner grants must also be captured).
The full changes can be found under Change ID-56 in the updated RMBS reporting guidance. IPs will be expected to adhere to the new definitions for all loans originated from 1 March 2019 onwards, when ADIs and registered financial institutions will commence reporting to APRA under the updated EFS requirements. However, institutions are strongly encouraged to report all loans according to these new definitions where feasible. Institutions may transition to the new definitions prior to 1 March 2019 and should notify the RBA at email@example.com if this occurs. Submissions made prior to the change will not need to be revised. For further information on the EFS reporting requirements see ‘Definitions standard and guidance’ published on APRA's website
Other changes to the reporting guidance
The RBA has also made a number of other minor changes to the RMBS, CMBS and OABS reporting guidance documents. These changes aim to provide additional clarity on the RBA's expectations around the reporting of certain fields in light of queries from IPs in recent times. There are two changes that the RBA would like to draw IPs’ attention to:
- Origination date settlement date. The RBA has removed the option of reporting ‘No data’ code ND1 for this field. Issuers reporting this value prior to 1 July 2018 will receive a warning. From 1 July 2018 onwards, use of this ND code will cause a submission to fail.
- Utilisation of exemption from reporting income data for loans originated prior to 1 January 2010. IPs utilising this exemption should report ND1 for the affected loans, not ND5. IPs that continue to report ND5 in these circumstances will receive warnings for rule LN0066(ND5). It is expected that this rule will switch to a fail severity (with a small tolerance) at some point in the future.
Below are the updated reporting guidance documents:
Please contact the Securitisation Support Centre at firstname.lastname@example.org or 1800 919 211 to seek further clarification.