Changes to the Securitisation System Reporting Guidance
The RBA has made a number of changes to the Securitisation System reporting guidance to strengthen data quality in the system and address common areas of confusion in the existing guidance. Draft versions of the updated guidance are published below. Information Providers (IPs) are invited to provide comments to the Securitisation Support Centre (SSC) by Friday 23 June 2017. Final versions will be published on the SIF on Monday 3 July 2017.
IPs are encouraged to begin reporting to the new guidance as soon as is practical. To assist with this the RBA will be switching on a number of validation rules from August 2017 onwards that will provide submitters with a ‘warning’ that their submission is not consistent with the updated guidance. These validation rules will not switch to a ‘fail’ severity, which results in a submission being rejected from the system, until 1 July 2018 (i.e. IPs have 12 months to bring their submissions into line with the updated guidance).
There are no new data fields or changes to the structure of the existing XML templates. Instead, the changes represent a limiting or expansion of the available options for some fields, additional guidance to help IPs understand what is expected for certain fields/scenarios or changes to the frequency of data updates that are required. The main changes are as follows:
- The static ‘issue date’ stratifications required for ‘Other ABS’ will need to be updated each month with data as at the collateral date. This will allow the RBA and other data users to more effectively monitor changes in the composition of the collateral pool over time, particularly for deals with revolving collateral pools.
- The addition of a list option ‘8 – Foreclosed’ within the acceptable range of responses for the loan account status field in the RMBS and CMBS templates. This addition simplifies the reporting of loans going through foreclosure and makes clear when a loan should be considered active/in the collateral pool or inactive/out of the collateral pool.
- Additional guidance around the reporting of loans ‘exiting the pool’. This change clarifies the reporting requirements for loans in the first month that they are inactive/out of the collateral pool, particularly for loans that have completed the foreclosure process (see the ‘Guidance Notes’ within the RMBS and CMBS guidance documents).
Restricting the use of ‘No Data’ (ND) codes.
- ND2, ND3 & ND4 will no longer be accepted by the system. These ND codes were designed to assist in the transition to reporting to the RBA and are no longer relevant.
- ND1 – Data not collected at loan origination – will not be allowed for loans originated on or after 1 July 2018. ND1 may be used for loans originated prior to this date but the RBA reserves the right to revoke repo eligibility for inappropriate or excessive use of the ND1 code.
- Additional guidance on when the use of ND5 – data not applicable – is appropriate for loan-level fields. In particular, the changes make clear that ND5 should not be used for active loans/loans in the collateral pool, unless the field is genuinely not applicable. Further guidance around when an ND5 might be appropriate for specific loan-level fields is also provided.
Below are the draft versions of the updated reporting guidance documents:
For further information or to provide comments please contact the Securitisation Support Centre at email@example.com or 1800 919 211.