The World Council of Credit Unions filed two comment letters urging changes to benefit credit unions on the Basel Committee on Banking Supervision (Committee) Consultative Documents on the Criteria and Capital treatment for simple, transparent and comparable  short-term securtisations.

WOCCU supports the Committee's efforts to revise the securitization framework to assis the financial industry in the development of simple, transparent and comprable (STC) term securitzation structures for short'term securitization such as asset-backed commercial paper.  The rules could provide a framework fora  more stable funding source for issuers and make it a safer and more attractive investment.

However, WOCCU urged several adjustments to the proposal to make the market friendlier to credit unions as follows:

• Allow asset-backed commercial paper to be sponsored and backstopped by a consortium of smaller financial institutions;
• Permit loans made to borrowers with low credit scores or who have a history of bankruptcy to be included in asset backed commercial paper collateral pools;
• Provide further clarification and guidance on establishing the "homogeneity" requirement for STC asset-backed commercial paper;
• Provide flexibility in establishing asset performance history by reducing hter minimum track record period for retail and non-retail exposures (no more than two years as opposed to the proposed five years); and
• Provide flexibility and clarity on meeting experience requirements.