S110 reporting requirements for SPV's

In October 2015, the Central Bank finalised and issued increased reporting requirements for Irish Companies that are registered with the Irish Revenue Commissioners under section 110 of the Taxes Consolidation Act 1997 (‘SPVs’). The aim of which is to improve the oversight of the Structured Finance sector. The new reporting requires all SPVs, or agents nominated on behalf of SPVs, to report quarterly to the Central Bank. The first period of reporting begins in Q3 2015 and is due on 20th November 2015.

Prior to this, the requirement to report quarterly only applied to SPVs that:

  • carried out one or more securitisation transactions and were insulated from the risk of bankruptcy or any other default of the originator of the securitised assets; and
  • issued securities, securitisation fund units, other debt instruments and/or financial derivatives.

The scope of quarterly reporting for all SPVs now include; details of all assets and liabilities, derivatives held by the company, movements on deposits and securitised loans. As well as details of counterparties and maturities/geographical information of all securities. In addition, as part of Q4 reporting, an annual profit and loss statement is required to be submitted for all SPVs.

The Central Bank aims to compile all statistical data on SPVs to allow financial stability analysis and improve regulatory monitoring going forward. This will ensure the Central Bank’s compliance with reporting obligations set out by the European Central Bank (ECB). The main benefit is the constant availability of accurate and relevant information on the industry provided as a result of increased reporting. Which once shared, offers advantages in understanding the activities and trends of the industry.

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