This is a reprint of an article originally published on 16 March 2022 as part of our publication "Structured Debt in a New World", accessible here.

The UK’s withdrawal from the EU continues to present a number of challenges for parties doing cross-channel business. The securitisation regulatory frameworks in the UK and the EU, once unified, have already begun to diverge in substance as well as form. This has meant market participants need to consider which of the regimes apply to them and to their transaction counterparties, and what compromises are necessary to continue to get deals done.

In this article, we examine some of the divergence that has already happened, consider areas of possible future development of each regime and review how market participants are managing the increased complexity that results from having to comply with the new regulatory landscapes.

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