SIFMA provides comments to the European Securities Markets Authority (ESMA) on the Consultation Paper on CRA3 Implementation, Draft Regulatory Technical Standards (RTS) on information on structured finance instruments (SFIs).

SIFMA expresses support for the comments submitted by its European affiliate the Association for Financial Markets in Europe (AFME), and in particular, their concerns regarding the potential for extra-territorial application of standards implemented under this rule and conflicts of law or regulation that may arise.

In addition, SIFMA members are concerned that the disclosure requirements, and other required actions, of the final RTS may not align with the obligations of U.S. entities under the current, or the revised, Regulation AB and other securities laws.

See Also: AFME Letter to ESMA on the Consultation Paper on CRA3 Implementation (April 10, 2014)