You may remember that the reporting templates for “structured financing products” under Article 8b of CRA III which were set out in the annexes to CRD 2015/3 were never used, and were then overtaken by Article 7 of the Securitisation Regulation, which has similar but different disclosure requirements. Article 43(8) requires the CRA III templates to be used until new ones are adopted under the SR, and the timing for that is after the SR becomes live on 1st January 2019. ESMA seems to have concluded that this transitional idea is not very good, so it has announced it will issue new templates by mid-July so that they can be adopted by then.