In my opinion there is nothing wrong with SBBs, they are useful in managing liquidity and capital optimization.
The regulator should do two things:
1. Legislate to ensure that the 2nd leg transaction is enforcable. This is easy to do by either limiting participance to banks under CBK or use of bank/legal undertakings.
2. Document neatly, how these items will be reported in balance sheets of instituions such as banks, insurers and others.
CMA is lazy.
"I'd rather be lucky than clever... every time!" - ME
"The problem is not what we don't know... it's what we know for sure that just ain't!" - MARK TWAIN
"Space we can recover... time never!" - NAPOLEON BONAPARTE