Liikanen Ripples Continue To Spread

In March of this year we alerted you to two European Commission regulatory proposals in the fields of (i) structural reforms of EU banks and (ii) reporting and transparency of securities financing transactions ("SFTs") – click here to see our previous alerter.

On 24 October 2014, the European Council published a compromise proposal that subtly alters the second of the original proposals in a number of respects. The three broad requirements remain (i.e. reporting of SFTs to repositories, disclosure to investors and prior consent to rehypothecation) but, among other things, the compromise proposal suggests:

• that the reporting obligation should extend beyond the entry into SFTs to their subsequent amendment or termination;