Where no prospectus is issued, Article 7(2) of the Securitisation Regulation states that an SSPE still has to make information available (to noteholders, regulators and, on demand, to potential investors) but it does not need to do it using a securitisation repository. ESMA’s draft RTS on disclosure have not been adopted because of widespread industry concerns. Meanwhile the FCA/PRA statement (as the competent national regulator) states that they intend to make a direction on 15th January 2019 that, for private issues, only “a summary of the relevant information” has to be notified to them, and the annexed reporting template is just an 18-row spreadsheet. It’s a very light touch. This is contemplated by section 25 of the UK Securitisation Regulations 2018, which come into effect on 1st January 2019. This does not – and cannot – disapply Article 7. Noteholders and, on request, potential investors, remain entitled to the full Article 7 disclosure (subject to Article 7(1), which has a paragraph that permits just a summary of the deal documentation to be provided rather than copies of all the bible documentation).