Questions & Answers

Implementation Arrangements

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How should the Reporting Frequency and Refresh, columns I and J, of the consolidated reporting guidance be interpreted?
Implementation Arrangements

It is expected that loan level data will be updated monthly even where no distributions from the trust have occurred. All fields relating to loan/pool level items (including pool rollups) should be updated monthly based on updated collateral information. The refresh indicator of 'M' is used as a guide to indicate which fields this may encompass. Other items, which are not based on collateral information, are also expected to be updated monthly regardless of whether a distribution has occurred (e.g. Report Date, Next Report Date). Items classified with a Reporting Frequency of ‘Dynamic’, but for which the Refresh indicator is blank, are expected to be updated in line with distributions from the trust (which may or may not be on a monthly basis). In periods where no distributions have occurred these fields should be reported as the last available value (for stock items) or as a 0 (for flow/distribution items). Static items may still update from period to period but these fields are not expected to change frequently.

Will the lodgement deadline for the submission remain defined in calendar days rather than business days?
Implementation Arrangements

Yes the deadline for submissions is 7 calendar days after the distribution date or the monthly anniversary of the distribution date. Outside of that date the RBA reserves the right to revoke the eligibility of any securities associated with that deal. Under exceptional circumstances where multiple consecutive public holidays make it difficult for an IP to report this information within the 7 calendar day window, the RBA will consider extensions. However, this is only done on a case by case basis and the IP will need to contact the RBA and make the case for why the submission cannot be made within that period. Effective 1 March 2018, reporting through the Securitisation System will be due on the monthly anniversary of the distribution date (i.e. the 7 day reporting allowance is being removed).

For the 30 June 2015 implementation date, is the RBA expecting May data to be provided in the first submission?
Implementation Arrangements

The first submission is due on the next distribution date or the monthly anniversary of the distribution date set to fall on or after 30 June 2015. The data should reflect the latest data captured at that point including data from previous months (for static items). For example, if the deal has a semi-annual distribution cycle (1 March 2015 to 1 September 2015) and the next payment occurs on 17 September 2015 then the first submission should occur for 17 July 2015 and it should have static data from the last payment date on 17 March 2015 and updated loan level data for the July Collateral Date (which is expected to be updated monthly) even if the collection period follows a semi-annual cycle. Please note that we would also expect any distribution-related items in the submission to be populated with zeros ("0") if no distribution is set to occur in this month.

For securities with coupon payment frequencies of greater than one month, what reporting is required?

Monthly reporting is required for all securities, including those that have a coupon payment frequency greater than one month. The reporting date should be on the monthly anniversary of the regular payment date. For any fields relating to distributions these should be recorded as zeros ("0") if no distribution is set to occur in that reporting period.

The RBA has included ‘No data’ (ND) options in data templates. For data fields completed with ‘No data’ options, can you confirm that we will not be required to provide missing data by 30 June 2015?

From 31 December 2015, the No Data 1 (ND1 – data not collected at origination), No Data 5 (ND5 – Data not applicable) and No Data 6 (ND6 – Data not collected reason being Pending Sale (RL053)) replies will be the only permitted use of ‘No Data’ replies for any missing data. If, from 30 June 2015, a large number of data fields feature ND1 replies, the Bank reserves the right to make the security ineligible for repo.

Does an Information Provider need to submit a glossary, which outlines field definitions, methodology and calculations used, to the RBA?
Implementation Arrangements Validation

No. A separate glossary, which outlines field definitions, methodology and calculations used, is no longer required by the RBA.

Is the RBA able to advise ADIs regarding specific format questions further to guidance notes and descriptions provided with the published templates?
Implementation Arrangements Validation

The RMBS XML Schema and associated support documentation available on the Support Material page, as well as the templates published on the Data to be Reported page, detail the formats for each of the specified data fields and provide guidance on the data required to be reported.

If a loan was removed from a pool and re-securitised into another pool the same month, should this be reported in the original pool's loan level template and/or the new pool's template?
Loan Level Implementation Arrangements

If a loan exits the pool then limited fields for that loan must still be reported for the period in which the loan exited the pool. The fields to be reported are: RL001, RL002, RL003, RL004, RL009, RL010, RL012, RL013, RL026, RL049, RL054 and RL055. If the loan enters a new pool which is also subject to RBA reporting requirements then all loan level fields for the loan would need to be reported for the loan in its new pool. In other words, the loan would be reported for both pools: with limited fields for the old pool, and with all fields for the new pool.

According to the table of implementation arrangements for RBA Repo Eligible Securitisations, reporting requirements for Borrower income data fields (RL090 and RL092) can be waived for loans originated before 1 January 2010. Do I need to use an ND code? If so, which one?
Loan Level RL090 RL092

While there are grandfathering arrangements, information providers are welcome to submit loan-level data to the RBA. Whenever a particular data field is not submitted, please use one of the six ‘No data’ (ND) options to indicate the reason.

Is the RBA going to add more data fields in data templates in the future?

There will be no further changes to the RMBS data requirements ahead of 30 June 2015. If there are any changes to data requirements after this date, industry will be given a minimum of six months lead time to implement any changes.

What is the implementation date for the new reporting requirements for repo-eligible residential mortgage backed securities?
Implementation Arrangements

The RBA's new reporting requirements for repo-eligible residential mortgage backed securities will be implemented on 30 June 2015. A single XML file must be lodged with the Bank no later than seven calendar days after the RMBS Trust issuer's specified coupon payment dates, or distribution dates (or monthly anniversary of the distribution date) on or after the implementation date. The data must also be made publicly available. The RBA will accept voluntary RMBS data submissions from 31 December 2014.