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There had been much disquiet over the impact on managed CLOs of the "skin
in the game" requirements. However, as arbitrage economics and investor
sentiment become more favourable for European CLO issuance, structures
were coming to market which sought to comply with the spirit of Article 122a in
a way which did not render managed CLOs uneconomical. The approach used
in such structures has now been cast into doubt by the Consultation Paper
published by the European Banking Authority.

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