CRE structured.credit collects short, practice-oriented notes on the structured-credit toolkit that sits between the traditional senior bank loan and pure private credit in European commercial real-estate finance — CMBS, synthetic securitisation and the pursuit of Significant Risk Transfer (SRT), fund finance (including NAV lines and CFOs), back leverage, and other bespoke structures. They are written as a personal working document — a way of mapping a moving target in a form that is useful for quick reference as the Basel 3.1 / CRR3 re-plumbing of European CRE lending plays out through 2025–2027.

The author

Portrait of Dr. Thomas Prüm

Dr. Thomas Prüm, LL.M. (NYU) is an attorney-at-law (Rechtsanwalt) and partner at Bryan Cave Leighton Paisner LLP in Frankfurt. His work focuses on structured finance, securitisation and financial-services regulation, with a particular interest in the structured-credit toolkit now re-shaping European CRE lending.

Full professional profile →

Editorial approach

Each product page follows a consistent pattern: a short framing at the top, a market snapshot with the most recent 2025/26 data, the regulatory framework, and the principal legal issues for practitioners. The aim is to be precise without being exhaustive — CRR3, the Securitisation Regulation, EBA Guidelines, the PRA and ECB supervisory pronouncements remain the authoritative sources.

Where there is a live policy debate — for example on the GRT tests applied to CRE reference pools in synthetic securitisations seeking SRT recognition, the circularity between back leverage and junior-tranche investors in such transactions, or the appropriate treatment of rated-note feeders and CFO securities under the Securitisation Regulation — these notes try to flag the state of play rather than to predict its outcome.

The site intentionally does not cover specific transaction advice. It is a notes site. Short definitions of the technical terms used throughout the site are collected in the Glossary.

Companion sites

CRE structured.credit is a companion to two other personal-notes sites by the same author:

absdata.de — Notes on EU Securitisation Law. The EU securitisation framework itself, with a focus on the Securitisation Regulation, STS criteria, transparency and due-diligence obligations, risk retention, and their interaction with CRR3. The original home of the April 2026 briefing dossier republished here.

railreg.de — Notes on Rolling Stock Financing in Germany. Rolling-stock financing, the 28 SPNV Aufgabenträger, Regulation (EC) 1370/2007, Directive 2012/34/EU and ERegG, vehicle authorisation / TSI and ECM.

Contact

For corrections, substantive feedback or questions about a specific note, please write to admin@cre-structured-credit.com.

Important. The notes on this website are personal, do not constitute legal advice, do not reflect the views of Bryan Cave Leighton Paisner LLP or any of its clients and do not create an attorney-client relationship. For legal advice on a specific transaction, please consult your own counsel. The full legal notice is available on the Disclaimer page.