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.