| Structured Finance Brief - New ECB Reporting Requirements for Irish SPVs |
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| From the end of this month, the European Central Bank (“ECB”) will require many categories of special purpose vehicles (“SPVs”) stablished in the Eurozone for domestic and international structured finance transactions to notify the relevant national central bank (In Ireland, the Central Bank of Ireland (the “ICB”)) of their existence as “financial vehicle corporations” (“FVCs”). Beginning with the period nding 31 December 2009, all Irish FVCs must report extensively to the ICB in relation to their end-of-quarter outstanding liabilities and uarterly financial transactions and write-offs/write-downs of their assets and liabilities. Reports must be submitted within 17 working days of he end of the quarter to which they relate and many service providers, arrangers and originators consider that it will be impossible to collate information in the required manner. At the same time, the ECB may impose significant financial penalties on FVCs that default in their otification or reporting obligations. Accordingly, it is important for transaction parties engaged with Eurozone SPVs and the SPVs themselves immediately to consider whether the entity is liable to notify its existence as an FVC and if so, what can be done to ameliorate unworkable reporting requirements flowing from FVC status. |
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