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Six products, one re-engineering playbook
CMBS, synthetic securitisation (the product by which SRT is most commonly pursued), fund finance, CFOs, back leverage and other bespoke structures. Complementary rather than competing tools answering the same question: how does capital reach a European CRE borrower when the Basel regime no longer lets banks hold that exposure efficiently on balance sheet.
Basel 3.1 / CRR3 and the capital squeeze
The output floor, the revised real-estate SA, operational-risk overlays, the EU / UK / US divergence on implementation timelines — and why each of the six products sits inside a single regulatory logic rather than on its own track.
Curated short analyses
A deliberately curated set of short notes on market and regulatory developments affecting European CRE structured credit. No news feed — just take-aways for practitioners.
RegulatorySecuritisation Regulation 2.0
Basel 3.1 sets the cost of holding CRE risk; the review of Regulation (EU) 2017/2402 sets the cost of moving it. Where the file stands, what is still open, and what it means for a private CRE transaction.
Sources, dossier, companion sites
The April 2026 briefing dossier as a PDF download; primary sources (EBA Guidelines on SRT, CRR3, PS1/26, ILPA NAV guidance); and pointers to absdata.de and railreg.de.
Key data points — 2025 / 2026
What this site is — and is not
CRE structured.credit is focused squarely on the structured-credit toolkit that sits between the traditional senior bank loan and pure private credit in European CRE. It is written as personal notes by Dr. Thomas Prüm and is designed as a companion to absdata.de (EU securitisation law) and railreg.de (German rolling-stock financing).
These notes are not legal advice and do not create an attorney-client relationship. For the full legal notice, see the Disclaimer.
Recent notes
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2026-07-13Regulatory
Trilogue: agreement on unfunded credit protection and the due-diligence waiver
The threshold for unfunded credit protection by insurers falls from EUR 15 bn to EUR 10 bn, the first-loss guarantee for the due-diligence waiver from 15% to 10%. Investor-side sanctions remain unresolved. Next session 29 September 2026 — state of play on Securitisation Regulation 2.0.
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2026-05-05Regulatory
ECON adopts its position on the Securitisation Regulation and the CRR
Both files carried by 33 votes to 25. Parliament wants the “resilient securitisation” category deleted but, unlike the Council, keeps investor-side sanctions. The capital calibration matters more to CRE than the process relief: for non-STS positions the p-factor moves the wrong way.
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2026-01-05SRT
ECB fast-track for simple, repeat SRT transactions
Together with the planned principles-based SRT test — at least 50% of unexpected loss transferred to third parties — the work shifts from individual approval to programme documentation. The same question under US rules: Regulation Q.