SECURITISATION WITHOUT SECURITIES: LOANS ARE NOT NOTES FOR TAX PURPOSES by Norman Pepe & Fabrizio Occhipinti

In December 2020, the Italian Budget Law for 2021 introduced, in addition to the traditional
asset-backed notes, an alternative funding tool for Italian securitisation vehicles
(the “SPVs”).

Now SPVs may fund the acquisition of assets in securitisation transactions through
the proceeds of ad hoc financings in the form of loans advanced by lenders authorised to grant
loans in Italy.