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Abstract

This article focuses on national variations in the engagement of banks in off-balance sheet securitization in three case study countries: Spain, France and Germany. It is argued that the failures in prudential regulation that underpinned the recent financial crisis are not predominantly situated at the international level. This article focuses on the way that national accounting rules determine whether the Special Purpose Entities of banks are off- or on-balance sheet. The analysis shows that national accounting norms are an important building block for prudential regulation, and these are prone to wider political influences.