Guide to Pre-positioning Loan Collateral

1: Executive summary

1.1: Introduction

The Bank of England Market Operations Guide sets out the Bank’s published framework for market operations conducted in support of monetary and financial stability.

When the Bank lends through our operations, we manage counterparty risk by securing our lending against collateral posted by members of the SMF. The Bank accepts a broad range of collateral in the SMF, split into three levels (Table A).

Portfolios of loans are eligible as Level C collateral, with the requirement that these must be pre-positioned in advance for us to lend against them in our facilities.^{footnote [1]} Eligibility requirements apply to the participant, the pool and the underlying loans and criteria are available on our website.

The purpose of this Guide to Pre-positioning Loan Collateral is to support SMF participants (‘you’) in pre-positioning loan collateral with the Bank, as part of preparing that collateral for use in the SMF.

It provides guidance on the pre-positioning process for:

• participants applying to pre-position a pool of loan collateral for the first time; or
• existing loan collateral participants applying to pre-position a pool of loans of a different asset type than they have before.

The pre-positioning process is designed to assure us that we can efficiently and effectively value and risk manage the assets – and that we can confidently take legal ownership of the assets if necessary. The process and requirements for pre-positioning loan collateral are consistent, regardless of the facility which the collateral is used for.

This guide provides a general overview of our pre-positioning process; processes may differ for some participants or collateral depending on specific circumstances. It is meant to provide helpful practical information; but in the event of any conflict with the SMF terms and conditions, the terms and conditions prevail.

1.2: Key documents and links

This guide should be read with the following documents as they collectively provide essential context and detail:

• The Bank’s SMF Terms & Conditions and Operating Procedures
• Level C Loan Collateral: Eligibility Criteria
• Additional Guidance for Loan Collateral
• Guide to the Management of Loan Collateral – this guide outlines the requirements for managing loan pools after completing the pre-positioning process

Across this guide there is reference to our Eligible Collateral page, which provides helpful information and documentation to support the loan collateral pre-positioning process (including pro forma documents and links to relevant data templates).

1.3: Pre-positioning process

Our pre-positioning process includes a number of elements, which are designed to:

• provide us with assurance on practices that can affect collateral quality eg:
  • loan origination and servicing policies
  • risk management practices
  • management information
• identify risks that may prevent us from realising some, or all, of the value of the collateral
• identify financial risks in the collateral and enable us to manage them (for example, financial risks from special loan structures)
• ensure we are able to appropriately value the collateral and set haircuts

The diagram below summarises the main stages of our pre-positioning process; subsequent sections of this guide go through this process in more detail.

Stage 1 – preliminary review

Stage 2 – full review

Stage 3 – pre-positioning loan pool(s)

1.4: Pre-positioning timeline

The table below sets out typical timelines for each stage of the pre-positioning process, from the first contact to operational pre-positioning of the loan pool(s).

In our experience, a number of factors can influence the timings for each stage. The table helps to identify areas where participants can take steps to expedite the process. Some overarching factors include:

• the provision of clear and complete information during the process;
• your continued engagement throughout the process, for example providing prompt responses on follow up queries; and
• the heterogeneity and complexity of the assets.

We would typically notify you if there is likely to be a material delay in progressing your request, for example because of operational reasons or high operational demand.

1.5: Costs

The primary external expenses incurred by participants relate to the required third-party data audit and legal reviews. Legal work conducted both for the participant and for us will be charged back to the participant under the terms of the SMF.

We have a panel of legal counsel to advise on legal risks in relation to loan collateral. This ensures there is sufficient capacity and that the fees charged remain competitive. In some cases where feasible, we have agreed with our legal advisors on a fixed fee structure for our legal costs.

You may also incur internal costs, for example preparing data reporting or creating appropriate governance and controls.

2: Loan eligibility process – stage 1: preliminary review

2.1: Initial contact

To initiate the pre-positioning process, your primary point of contact is the Bank’s Markets Directorate. These teams are available to assist with a range of queries.

Contact information

The Bank’s Collateral Team (within Financial Risk Management Division, FRMD) is responsible for the assessment, pre-positioning and ongoing management of loan collateral.

You will be assigned a lead collateral contact (‘collateral contact’) from the Collateral Team, who will be the main point of contact regarding the pre-positioning of portfolios, and potentially a back-up collateral contact. In email communications, copy in both the collateral contact and any back up collateral contact. If you have multiple asset types, you may be given different contact points within the Collateral Team for each asset type.

Loans within the proposed loan portfolio must meet our eligibility criteria. Where you are unsure, you can contact the Collateral Team to discuss your plans.

We encourage you to discuss plans with your PRA supervisor and keep them updated during the process. The Collateral Team works closely with PRA supervisors to share information, including access to regulatory submissions.

2.2: Screening call

Following your initial contact with us, your collateral contact will arrange a call to talk through the pre-positioning process, obtain more information on the collateral you are planning to pre-position, and answer any initial queries. This initial information will contribute to the screener stage.

For SME, Corporate, PFI and Social Housing pools your collateral contact will share a legal checklist, which aims to identify legal barriers around pre-positioning the loans that may affect eligibility.

2.3: Screener

Before we proceed with detailed work to pre-position the loan pool, a screener of your proposal is taken to our internal collateral review committee.

To support your planning, the screener will be used to assess:

• if the assets are likely to meet our eligibility criteria
• if changes should be made to the scope of assets proposed
• whether to proceed to the full review stage of pre-positioning

To avoid unnecessary costs, we encourage you not to engage third-parties to conduct legal and/or data reviews ahead of the proposal being screened.

To proceed with the screener, you will need to provide adequate and accurate information on the following:

• summary of the assets: a summary of the proposed collateral and the potential number of pools;
• information on the assets: asset type, homogeneity, pool size, number of loans, granularity/concentration, whether these assets have been securitised previously;
• loan origination: details of who originated the loans (firm or a third party), copies of underlying loan underwriting policies, explanations of processes for the life-cycle of the loan;
• data: confirmation that you can meet our reporting requirements and provide the necessary performance data;
• legal: details of the documentation backing the loans, including whether they are standardised or there are variations; and
• lending history: you should be able to show a reasonable track record of historical lending.

After completing our internal screening, we present the proposal to our internal collateral review committee and then let you know the outcome.

There are three possible decisions:

3: Loan eligibility process – stage 2: full review

3.1: Loan pool composition

We have some headline requirements for loan collateral, as set out in our Level C Collateral: Eligibility Criteria – and additionally:

• loans should have a low expected probability of default as determined by us and evidenced by your internally or externally assigned rating, or as otherwise agreed with us; and
• loans should be a representative sample of your loan book and not be adversely selected.

Operationally, loan collateral is structured into ‘pools’ where loans are grouped and referred to collectively under one unique pool identifier.

You have discretion on how the loan collateral is split into separate pools but there are some factors to consider when determining this, including:

• pools should contain homogenous assets. Individual assets classes should be in separate pools – eg residential mortgages and consumer loans cannot be combined into one pool. Product types within asset classes can either be kept in separate pools or be mixed within pools – eg owner-occupied (OO) and buy-to-let (BTL) can either be separate or mixed within the residential mortgage asset class;
• loans written under the laws of England, Wales and Northern Ireland can be included in the same pool, but loans written under Scottish law must be held in a separate pool – this is because of the differences in legal mechanisms across jurisdictions that are used for transferring the collateral to us;
• grouped by brand, IT system or legal risks; and
• you may split large portfolios into smaller pools of varied sizes – but given the operational overheads required for processing multiple pools, four or fewer pools are typically sufficient to support your collateral activity.

We prefer pools which are as granular and diversified as possible, including across borrowers, geography, vintage, and product types (More information can be found in Box A for the minimum loan seasoning and Box B for the borrower concentration limits). To mitigate risks from concentrated pools, we may apply higher haircuts, or in certain cases deem pools ineligible, for example if they do not meet our granularity requirements as set out in our Level C Collateral: Eligibility Criteria.

You will need to read section ‘2: Eligibility and loan pool composition’ of the Additional Guidance for Loan Collateral for further details and support in determining your loan pool composition.

3.2: Loan level data tape(s)

To conduct our analysis, we require a completed loan level data template for each proposed loan pool. Data tapes have two core purposes:

• to define which loans are included within the pool and are therefore being used as collateral; and
• to provide us with visibility of the individual loan characteristics to determine a suitable haircut for the portfolio.

In order to risk manage raw loan pools effectively we have prescribed data templates for each asset class, which broadly follow market standards. These data templates are found on our Eligible Collateral page (under ‘Key resources’).

You should read section ‘4: Loan data tape’ of the Additional Guidance for Loan Collateral, which provides detailed instructions and support on completing a data template accurately.

Data fields in the template are defined as either ‘mandatory’ or ‘optional’:

• mandatory fields are essential to enable us to calculate a haircut or to enable transfer of legal ownership. An inability to provide these data will mean we may not be able to make the pool eligible, so where mandatory fields cannot be completed, this should be discussed with your collateral contact as soon as possible; and
• where optional fields are not completed, we may make conservative assumptions that affect haircuts. Therefore, it is in your interest for the data tape to be as complete and accurate as possible. We also regularly review which fields should be mandatory, so a comprehensive data tape is recommended.

We place strong emphasis on the accuracy and consistency of your data as it is core to our valuation and calculation of haircuts. You are expected to have robust systems and controls in place to ensure data submissions are of the highest quality. Our site visit and third-party reviews are also intended to obtain evidence of an accurate and well-controlled data tape production process. Where data quality does not consistently meet requirements, we reserve the right to apply higher haircuts or in some cases withdraw eligibility of a pool.

Prior to the site visit, a data tape must have been submitted to the Loans Data Portal and the data tape should have passed validation. This ensures that data submitted is in the correct format and mandatory fields are completed with acceptable values etc. This helps ensure the visit remains focused on the proposed loans and minimises the need for further follow up queries. You may be requested to complete and maintain a data tape glossary, which records annotations to fields where you are unable to comply or have made assumptions regarding the most appropriate classifications (read section ‘4.3: Data glossary’ of the Additional Guidance for Loan Collateral for details). This will be discussed on the visit to identify gaps and queries.

All data tapes must be submitted via the Loans Data Portal, which will:

• assign each pool with a unique pool identifier – this identifier is used within the Loans Data Portal and for communications with us; and
• validate submissions – where data tapes do not meet our data requirements, we will let you know (via automated email) that the data submission has been rejected alongside an outline of the cause.

For further guidance and detail of how to access the Loans Data Portal please read section ‘5.2: Guidance to accessing the Loans Data Portal’ on this page.

You will need to confirm that pre-positioned loans can be clearly identified within your core IT system, for example through flags or hold codes. If you cannot confirm this, you will need to demonstrate satisfactorily how you intend to segregate the pre-positioned loans from your wider portfolio so that we can identify the collateral in the event that we need to take ownership of the loans following a default.

3.3: Due diligence questionnaire (DDQ)

We will require you to complete a due diligence questionnaire (DDQ). The DDQ provides an overview of the following aspects relating to the business line planned for pre-positioning:

• strategy and outlook
• underwriting and origination policies
• risk management, monitoring and controls
• servicing, arrears and foreclosures
• IT systems and data reporting

DDQ requirements:

• answers must cover all asset types intended to be pre-positioned (eg owner occupied and BTL mortgages). If necessary, responses should be split into sections to ensure each asset type is covered; and
• all applicable questions must be answered with a written response, supporting documents may be mentioned but there must always be an explicit answer to each question – otherwise, we may request a revised DDQ to be provided.

The DDQ requirements are periodically reviewed and updated to reflect changes in market and lending standards. The latest version for each asset class is available on our Eligible Collateral page under ‘Key resources’. If a proposed loan pool and the associated underlying processes are similar to one which has already been pre-positioned, DDQ responses should focus solely on specific differences.

All documents should be uploaded to the Loans Data Portal via the ‘Supporting Documents’ folder and you should contact your collateral contact to confirm documents have been received. No documents should be sent via email unless requested to do so by your collateral contact.

3.4: Site visit

As part of our assessment, we conduct a site visit to meet key members of the management team and to gain a qualitative understanding of the business and address queries related to the DDQ. Alongside the completed DDQ and supporting documents, we will require in advance:

• a copy of presentations planned for the site visit – presentations are not compulsory, though you may find slides helpful to highlight key aspects; and
• a validated loan level data tape for the proposed pool – this can be indicative if the pool has not yet been finalised.

Site visits usually will be organised to be no more than 4 weeks after the DDQ and data tape submission.

The visit follows the structure of the DDQ (an indicative agenda can be found below). Having reviewed the DDQ, we may request to focus on specific areas of interest. Each session should be led by representatives from the relevant business areas that are able to answer detailed questions regarding their area – eg the CRO or Head of Risk would attend the risk management section, rather than representatives from the central Treasury function.

Indicative site visit agenda:

• business strategy – focused on the business line being positioned
• origination, underwriting and servicing
• floor walk – including a session with an underwriter and servicer
• servicing, arrears and forbearance
• risk management
• IT and data tape(s) – system(s) and production
• audit and legal

The first agenda item should provide an overview of the business and the different product offerings, with a clear focus on the assets proposed for pre-positioning. The remainder of the day should concentrate on aspects related to the proposed business line. We also expect the visit to include a ‘floor walk’, which allows us to meet with an underwriter and servicer to discuss a recent case study to see how policies are applied in practice. In some instances, we may request for this session to be replaced with or complemented by an underwriting file review. A file review allows us to examine the underwriting documentation for a small sample of loans from the proposed pool. We will outline and explain any such requirements ahead of the visit.

Post site visit

After the site visit, no explicit feedback is provided although we may have some follow-up questions. If we have specific concerns, we may present the case to our internal collateral review committee for views before continuing with the process.

3.5: Third-party due diligence

After the site visit, we will confirm the audit and legal work required. We require two types of third-party due diligence to be completed on the proposed loan portfolio, as part of assessing eligibility and setting haircuts:

1. data audit
2. legal review

These reviews ensure we obtain a satisfactory level of assurance and should be conducted by suitable third parties (not your in-house/internal audit or legal functions) and appointments are made at your expense. If you want to, you are free to engage your external auditor or outsourced internal auditor (for the data audit), or your external legal counsel (for the legal review).

In our experience, using firms who are familiar with our requirements for collateral data audits and legal reviews may ensure a smoother and quicker process. Once firms have been chosen you will need to inform your collateral contact. Typically, these are commenced and run in parallel to each other. Additionally, proactively engaging with your chosen firms throughout the process may reduce delays.

You should not commence either the data audit or legal review until your collateral contact has provided the necessary requirements.

3.5.1: Data audit

The purpose of the data audit is to verify the existence of the loans and offer comfort on the quality and ability of your systems and processes to produce accurate data. The data audit follows an Agreed-Upon Procedures (AUP), including data validation and analysis confirming compliance of the loans with our eligibility criteria.

More information on our broad requirements on sampling and confidence levels can be found in Box D.

The tests required for each asset class are detailed on our Eligible Collateral page under Data audit AUPs and results tables. Most AUPs tests will relate to the data fields included in the loan level data template, but others relate to aspects of the loan agreements that are required to enforce legally on the loans (eg names, addresses, title registration, signatures completed). The AUPs specify whether the data should be checked to the primary system of record, original documentation, or both. Other than those listed in the AUPs, we do not grant tolerances on tests which means any discrepancy between the data tape and source material is marked as a fail.

Once complete, we will review the results of the data audit and consider whether they have a material impact on our ability to risk manage the portfolio. In this case we may apply risk mitigants, such as the removal of certain loans, additional haircuts, or potentially the pool being deemed ineligible for use in our operations.

3.5.2: Legal Review

The legal review can be the most time-consuming part of the pre-positioning process. Four parties are involved: you, your third-party legal counsel, the Bank (the collateral contact and internal legal counsel) and our legal counsel. We have a panel of external law firms to carry out our legal work in relation to collateral reviews and your collateral contact will confirm which law firm your lawyers should contact.

Given the number of parties involved it is crucial that you remain in communication both with your legal counsel and collateral contact. We receive frequent updates from our legal counsel and will monitor progress. We will notify you of additional clarification questions or risks your legal counsel should focus on. All responses should go via the relevant external legal counsel, so that the final legal review can be updated to reflect the additional information.

Box E sets out each stage of the legal review in more detail. At a high level, the legal review is designed to confirm:

• the loan documentation does not prevent the mechanism for delivering the collateral asset to us from being effective, or impose conditions for the mechanism to be effective, such as the need to advise or obtain the approval of the borrower;
• the location, jurisdiction and governing law of the assets;
• that the loans are valid, binding and enforceable against the underlying borrower;
• compliance with consumer credit requirements, where applicable;
• that the loans are originated in the ordinary course of business and have not been terminated, redeemed, or cancelled; and
• you have an effective charge over any collateral used to secure the loan.

Where bespoke documentation is used, you should inform your collateral contact before initiating the legal review. Bespoke documentation can result in prolonged legal review, and higher cost. Some participants may instead decide to securitise loans in this case – and deliver the senior note as collateral.

Box E: Legal due diligence process

The stages of the legal review

Stage 1: your legal counsel

You should appoint an external legal counsel to complete a legal DDQ and legal opinion for the loan portfolio. Standard form legal due diligence templates for each asset class are available on our Eligible Collateral page.

You should inform your collateral contact of the legal firm you plan to engage with. Northern Irish and Scottish counsel should also be engaged, and separate reports completed on proposed loans governed by the law of these jurisdictions, given the different legal frameworks across jurisdictions. These will need to be split out into separate pools.

The legal DDQ requires your counsel to review and assess the terms under which the loans have been written. For large granular portfolios (eg residential mortgages and consumer loans), the standard form documentation (including possible variants) for all loans included in the portfolio will need to be reviewed.

In addition, a random sample of loans must be reviewed and your collateral contact will confirm the number of loans. Sample sizes will be 10, 25, 50 or 75, depending on the size of the pool. The sample should be selected randomly by your counsel (not by you). Similar to the data audit, there may be occasions where we specify a sample or divide the portfolio into homogeneous groups for the purposes of the legal review – for example, to ensure all asset types (owner occupied and BTL) or variants of standard form documentation are adequately represented in the sample. The loans selected for the legal sample do not need to be the same as the loans selected for the data audit sample.

The documentation for the sample loans will be reviewed to confirm that they conform to the standard form documentation, our relevant eligibility criteria and to identify issues that would undermine the effectiveness of the loans as collateral. If the sample contains incomplete documentation, this should be noted (and reasons for the incomplete documentation provided), and further files should be selected until the requested number of files have been reviewed.

For portfolios containing loans with bespoke documentation (eg for larger corporate loans, social housing or commercial real estate) an alternative approach is taken. Instead of the standard legal review, a core terms report is needed in respect of all of the loans in the pool, and a ‘deep dive’ DDQ is needed in respect of a chosen sample of loans.

Typically, the core terms report will include:

• status of incorporation of the borrower
• governing law
• restrictions on assignment of the loan (or creation of a trust) or transfer of servicing to a third-party, waiver of borrower’s right of set-off
• restriction on disclosure of information to us or third-party assignees/transferees, requirement for a confidentiality undertaking
• confirmation that certain events of default exist in the documentation

Stage 2: our external legal counsel

Your collateral contact will confirm the contact for our external legal counsel. Our external legal counsel will review the legal due diligence reports and opinions made available to us by you and your legal counsel and consider their implications for the pre-positioning of the portfolio.

We and our legal counsel may have further questions or require clarifications.

Prompt and proactive engagement from you and your legal representatives will facilitate a smoother and quicker review process. In our experience, incomplete reports and opinions are a common cause of delay in the pre-positioning process.

Stage 3: our internal legal analysis

Our internal lawyers and Collateral Team will review the analysis conducted by our external lawyers. There may be additional clarifications and queries that require input from you or your lawyers.

Once all queries are resolved, the legal work will be signed off and mitigating actions implemented as part of the eligibility proposal. This can include the removal of certain loans, additional haircuts, or potentially a decision that the pool does not meet our eligibility requirements. On the day of pre-positioning, a Conditions Precedent email is collated that brings together all legal documentation.

3.6: Eligibility confirmation

Once the requirements detailed in this section have been completed, the eligibility of the participant and portfolio is reviewed by our internal collateral review committee. Following the review, your collateral contact will inform you of the outcome. This may include confirmation of eligibility and applicable initial haircut, a request for further work/information in order to determine eligibility, or a decision not to make the participant and/or the loan pool(s) eligible.

There are three possible decisions:

Once a pool is deemed eligible and has been successfully pre-positioned it can be encumbered and used as collateral within our SMF Facilities (subject to the participant itself being an eligible member in the relevant scheme). The operational process to pre-positioning is explained in section ‘4: Operational process - stage 3: pre-positioning loan pool(s)’ of this guide.

3.7: Pool encumbrance and unencumbrance

We operate a collateral pooling model to support our SMF operations. Neither loan pools nor securities collateral are earmarked against individual lending transactions. Instead, the aggregate adjusted market value (ie post-haircut) of the collateral held in the Single Collateral Pool (SCP – and any sub-pools) will be used to collateralise the aggregate value of our lending under the SMF.

Once a loan pool is deemed eligible, your collateral contact will arrange with you to pre-position the pool. You can pre-position loan collateral into the Loan Pre-positioning Pool (LPP) where it will remain unencumbered. Loan pools in the LLP are ready to be transferred into the Single Collateral Pool– thereby legally encumbering the pool and enabling it to be drawn against.^{footnote [4]} Pre-positioning loan pool(s) in the LLP ensures that, even if there is not an immediate need to draw against the collateral, it is available at short notice.

If you wish to legally encumber the newly pre-positioned loan pool(s) (ie move loan pool(s) from the LPP to the SCP), this can be completed the following working day post pre-positioning. More information on how loan pools are to be managed once pre-positioned, can be found within the Guide to the Management of Loan Collateral.

Encumbered and unencumbered collateral pools

4: Operational process – stage 3: pre-positioning loan pool(s)

4.1: Prior to pre-positioning

Once eligibility has been confirmed, your collateral contact will outline the next steps:

1. legal transfer
2. operational instructions

Stage 3: pre-positioning loan pool(s)

Legal transfer

Before pre-positioning, you will need to complete and submit all relevant legal documentation, including:

Hard copies of the Annex, power of attorney, declaration of trust and any side letters (if required) may be required to be posted to our Loans Data team. These must be received ahead of the pre-positioning date. There are different versions depending on the asset type being positioned. We will confirm which document versions are required bilaterally and if there are any specific execution requirements.

We normally expect English and Welsh law-governed loans to be transferred as an equitable assignment, though this will not be possible in all cases. Where you believe that equitable assignment is not possible (eg restrictions on assignment contained in the underlying mortgage conditions), this should be discussed with your collateral contact to confirm whether transfer should be affected under a declaration of trust. Both methods of transfer have a separate annex to the existing SMF documentation, and these are available on our Eligible Collateral page under ‘Key resources’. Scottish law governed loans will always transfer under a declaration of trust.

Standard forms of all these documents are provided by us and are available on our Eligible Collateral page or by contacting us directly. We will provide further guidance during the pre-positioning process.

Operational instructions

Leading up to pre-positioning, your collateral contact will discuss and outline the operational steps to pre-position:

• a mutually convenient pre-positioning date will be agreed (Fridays are avoided where possible). You should ensure that your legal counsel is available on that date;
• you should sign (but not date) hard copies of all necessary legal documents - annex, power of attorney and side letters (plus declaration of trust documents where necessary). These must have been received by us in advance of the pre-positioning day. It may be possible to execute some documentation electronically, which will be confirmed in advance;
• you may be required to upload an up-to-date data tape(s), eg if a long time has elapsed since the initial tape was provided; and
• at the point of pre-positioning, you will be asked to confirm the arrears rates in the loan pool(s). Where significant, we may request any non-performing loans to be removed, and new data tape(s) will be required.

4.2: Day of pre-positioning

Your collateral contact will confirm detailed instructions in advance of pre-positioning day.

The following must be provided by 10am on the day of pre-positioning (delays may result in the movement being postponed).

• a nominal balance for the pool(s) to the Loans Data Portal;
• a Collateral In form including relevant details;
• legal counsel to execute and date legal documents previously approved and send copies to our external legal counsel. This should be completed as early as possible on the day of the pre-positioning. We encourage you to remind your lawyers ahead of the day. Our legal counsel will then collate the documents with its own reports and send us a Conditions Precedent email that brings together all the legal documentation; and
• pre-positioning will be confirmed by us once all above steps are completed.

Once the loan pool(s) has been successfully pre-positioned, you should read and review the Guide to the Management of Loan Collateral. This guide sets out our requirements for continued loan pool management after initial pre-positioning.

5: Information sharing – Loans Data Portal

5.1: Purpose

All sensitive data should be uploaded via our Loans Data Portal unless specified otherwise by your collateral contact.

Portal functionality allows the upload of loan pool data tapes. These uploads are directly linked to loan pool identifiers and can include any documents or data related to proposed pools.

All files should have relevant, clear, and descriptive names. No special characters should be used, and names should be kept as short as possible (eg the pool ID and the cut-off date, such as: ‘LOAN12345678 31032025’). Once files have been uploaded they cannot be edited or deleted by you. All files are strictly confidential and only visible to us. Files are not to be password encrypted, as this can lead to the files not passing through our security and communications being lost.

Access and user guidance is provided by our Loans Data team. It is your responsibility to ensure users retain access and remember log in details. For queries relating to the Loans Data Portal, including password resets or any other issues, contact LoansData@bankofengland.co.uk.

We will not publicly disclose loan level data. We may publicly disclose data that has been aggregated and anonymised such that the loan level details cannot be determined. Further information can be found in the SMF T&Cs.^{footnote [5]}

5.2: Gaining access to the Loans Data Portal

To set up access to the Loans Data Portal, you should complete and email the table below to our Loans Data team at
LoansData@bankofengland.co.uk. We use two-factor authentication so mobile numbers are needed to send users security authorisation codes. The last column is an email address to which validation emails will be sent (ie confirmation that the data tape submissions have been received and passed validation checks), group email addresses can be used for this purpose, to ensure wider awareness.

A maximum of three users is permitted. This is to provide sufficient coverage to account for staff absence to ensure operational continuity. Further users are considered if there is sufficient rationale.

6: Authorised signatories

When using loans as collateral you are required to sign documentation both at the point of pre-positioning and when encumbering/unencumbering loan collateral (post pre-positioning). The individuals allowed to do this on behalf of your organisation are detailed within an authorised signatory evidence form.

As a participant in the Sterling Monetary Framework, you are required to provide an authorised signatory evidence form and documentary evidence to support the authorised signatories. This form must be completed on behalf of your organisation and responsibility is with you to keep this up to date and inform us of updates or amendments in a timely and efficient manner.

To update the authorised signatory evidence form, please complete our proforma. Evidence of authority and specimen signatures are required for the individual(s) signing the form. We encourage you to read our guidance note on supporting evidence. Please submit your signatory form and/or questions to our Sterling Markets Division at
applications@bankofengland.co.uk.