ASF framework
ASF members, in conjunction with the RBA, have adopted a risk-based approach to the provision of loan level data to Permitted Users.
Whilst the release of such data is the responsibility of RMBS sponsors, the ASF framework is designed to promote the efficient operation of RMBS markets whilst mitigating certain risks relating to the loan level data by taking into account the circumstances of the Permitted User and the data requested.
The following framework is a recommended minimum standard for industry participants. Transaction sponsors responsible for the release of loan level data may adopt additional requirements at their discretion, or as circumstances dictate.
The key elements of the ASF framework relating to the provision of loan level data are:
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certain sensitive data that is provided to the RBA is not required to be made publicly available;
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information providers (sponsors) enter into ASF Data Access Deeds (i.e. non-disclosure deeds) with Permitted Users that, amongst other things, limit the purpose for which the data may be used;
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sponsors adopt a risk-based approach in assessing the safeguards that Permitted Users have in place to minimise any impact on individuals’ privacy.
Sponsor due diligence
The ASF recommends that sponsors undertake sufficient due diligence on each applicant requesting access to loan level data to ascertain:
- that the applicant is capable of being considered a Permitted User;
- the applicant’s ability to comply with the terms of the ASF Data Access Deed - RMBS;
- the risks associated with the applicant seeking access to the loan level data;
- that the applicant has appropriate safeguards in place to minimise any impact on individuals’ privacy.
Schedule 1 – User Information of the pro-forma “ASF Data Access Deed – RMBS” requires basic information about the applicant, their purpose for seeking access to the loan level data and information to assist highlight privacy risk factors.
Where applicant responses indicate that there may be higher privacy risk factors, additional due diligence is recommended to ensure that appropriate safeguards are in place to minimise any impact on individuals’ privacy. The Due Diligence Guidance Notes are intended to assist the sponsors further assess such risks.
If you would like to know any more about the Australian securitisation disclosure and reporting standards, please contact us at asf@securitisation.com.au.
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