SPIRE SA — Repackaging Programme Tracker

What SPIRE is

SPIRE is a Luxembourg public limited company (société anonyme) with the status of an unregulated securitisation undertaking (société de titrisation) under the Luxembourg Securitisation Act of 22 March 2004. It exists only to run a Secured Note Programme: it issues series of secured, limited-recourse notes, uses the proceeds to buy collateral (typically a government or corporate bond), and overlays a derivative (usually an asset/cross-currency/interest-rate swap) to reshape the cash flows for the investor.

It is a multi-dealer platform — a single, standardised issuance shell that many investment banks ("Dealers") use to structure bespoke repacks for institutional clients (insurers, pension funds). Each Series is issued through its own Compartment, so the assets and liabilities of one series are legally ring-fenced from every other series (segregated, limited-recourse). The Base Prospectus is approved by the Central Bank of Ireland; notes are typically listed on Euronext Dublin and/or the Luxembourg Stock Exchange.

How a SPIRE repack works

Investor(e.g. EU insurer) buys one secured note

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SPIRE CompartmentSPV / issuer (ring-fenced per series)

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Collateralbuys a bond (e.g. govt / corporate)

Swap Counterparty(dealer bank) reshapes coupon / currency / adds callability

The note pays the investor the combined cash flows of the collateral bond and the swap. The swap is collateralised inside the SPV (a CSA sits between the dealer and SPIRE), so the investor holds a single bond on its balance sheet and is freed from running its own ISDA/CSA, margin calls and collateral management. The note is a secured, limited-recourse obligation: recourse is only to that compartment's assets.

Why investors use them: yield pick-up / illiquidity premium, currency transformation (e.g. USD or JPY "Samurai" assets swapped to EUR/GBP), callable fixed coupons, diversification, and operational simplicity. Source: Nomura, J.P. Morgan AM (below).

Worked example — Series 2025-22

REPACK EUR 15,000,000 Auto-Callable Fixed Rate Secured Notes due 15 September 2041

Note ISIN	XS3142399974
Collateral (the "repackaged" asset)	Republic of Italy government bond — ISIN IT0004545890, coupon 2.550%
Derivative overlay	Swap with Nomura International plc (Swap Counterparty), guaranteed by Swap Guarantor; collateral valued at 90% (bond) / 100% (cash) under the CSA
Dealer / structurer	Nomura Financial Products Europe GmbH
Issue date	18 August 2025

This is the literal answer to "are they repackaged": SPIRE bought an Italian government bond and wrapped a Nomura swap around it to produce an auto-callable fixed-rate EUR note maturing in 2041. Series Prospectus (Euronext Dublin)

Series register

Seeded with publicly identifiable series. SPIRE issues series numbered YYYY-NNN; the count reaches at least the high-200s within a single year (e.g. 2023-295), so the full register is large and is published one prospectus at a time on Euronext Dublin / LuxSE rather than in one machine-readable list. Add rows in the data block to grow this over time. Click a header to sort.

Each column has its own filter box. Dates: =2026-01-01 exact · 2026-01-01 near (±30d, tune with ~7) · >=2026-01-01 · 2026-01-01..2026-06-30 range · 2026-03 prefix. Numbers take > < = and ranges. Text: words are ANDed, | is OR, =x exact, !x excludes.

Series	Note ISIN	FIGI	Ccy	Notional	Maturity	Structure	Collateral / underlying	Dealer / swap	Issued

Your example note XS2936521710 (FIGI BBG01QN43W76) is in the table as a stub. Its detailed terms aren't in any free aggregated source — resolve them with your OpenFIGI key and the security's series prospectus (see "Updating this page"). Note: a web search for that ISIN also surfaces the unrelated US gas utility Spire Inc. — ignore those.

Full issuance feed — every note under the SPIRE LEI (ESMA FIRDS)

No live feed loaded yet. Run python spire_tracker.py in this folder (with your OPENFIGI_API_KEY set) to generate spire_data.js, then re-open this page. The script enumerates every ISIN issued under SPIRE's LEI from ESMA FIRDS, enriches it with Bloomberg FIGIs via OpenFIGI, flags newly issued notes since the last run, and also writes spire_notes.csv.

Each column filters independently. Dates: =2029-06-15 exact · 2029-06-15 near (±30 days, tune with ~7) · >=2030-01-01 / <2028 · 2029-01-01..2029-12-31 range · 2029-06 month prefix. Notional / coupon: >50000000, 1..2.5. Text: words are ANDed, | is OR, =XS123… exact, !eur excludes.

ISIN	FIGI	Name	Ccy	Notional	Cpn%	Issued	Maturity	Redeemed	Status	Estimated underlying	Collateral ×	Funding	Venue

Estimated underlying is a maturity-matching heuristic against the sovereign-bond repository (US, UK, 10 Eurozone issuers, plus AU, CA, CH, NO, JP): exact-date match = high, within ±1 month = medium, no match = likely a corporate / non-covered underlying. Currency can differ from the note (cross-currency repacks), so candidates of any currency are shown. An inflation-linked note prefers a linker; the infl? flag means the closest match's inflation type disagrees (note: a few sovereigns, e.g. AU/CH/JP, don't label linkers in the source data, so their linkers can't be told apart from nominals). FIRDS does not give the actual collateral or swap counterparty — confirm via the Series Prospectus or Bloomberg. Status: redeemed early = a FIRDS "Terminated" record dated well before scheduled maturity (called / unwound / rolled).

Where a series document has been collected, the guess is checked against the collateral the document actually names: doc ✓ confirmed, doc ✗ the document names a different bond. On the 225 notes where this can be checked, the heuristic is right 93 times — 41%, including cases it labels high confidence. Treat the estimate as a lead, not a fact, and filter this column on doc-confirmed or doc-mismatch.

Funding flags deals where the collateral is not simply bought outright with note proceeds: repo backed (the SPV enters a Repo Agreement and the investor funds only the haircut), collateral borrow, and securities lending backed (collateral sourced under an SL Agreement). Pick ▸ any leverage for all three.

Amortising (instalment) is listed separately and is not leverage. Under Condition 8(b) Redemption by Instalments of the base prospectus, "each Instalment Note of a Series shall be partially redeemed on each Instalment Date… the outstanding principal amount of each such Note shall be reduced" — that is the issuer repaying the investor. The programme has no partly-paid concept.

Collateral × is the evidence-based column: collateral face per unit of note face, read out of the series document by prospectus/ and served from leverage_data.js. Above 1.02× (orange) the compartment holds more collateral face than the notes funded — a documented leverage candidate. Purple means the collateral cost above par while its face is 1:1, i.e. premium or inflation-linked pricing rather than gearing; the cash ratio alone has a median of 1.32 against a face median of exactly 1.00, which is why face is the headline. Green is a 1:1 repack, and — means no document was located. Click a value to open the source document; hover for the obligor, collateral ISIN and both ratios. Filter with >1.02.

Caveat: FIRDS publishes no issue price, so the series name is the only free signal here and it is demonstrably incomplete — a document check found Series 2024-160, named plain "Secured Notes", buying EUR 62.8m of collateral against EUR 50m of notes. The authoritative figures are the "Issue Price" and "Original Collateral Sale Price" lines in each series document; see prospectus/ for the pipeline that collects them.

Programme history

Base Prospectus lineage

The programme is refreshed by an annually updated Base Prospectus (Central Bank of Ireland approved), each accompanied by Master Trust Terms and Product/Collateral Criteria.

Dealer onboarding

Banks that have joined the multi-dealer platform (from SPIRE press releases).

Insurance / Solvency II treatment — do insurers "look through"?

Short answer: yes — they look through. A standard SPIRE note (untranched, secured, limited-recourse, SPV is a pure conduit) is not treated as an opaque structured note. EIOPA confirmed the look-through approach applies, so the insurer splits the note into its underlying bond + the derivative and computes the market SCR on those, exactly as if it held the collateral bond and the swap directly.

The basis

EIOPA Q&A 2321 (Article 84, Delegated Regulation (EU) 2015/35) — which uses a "default-remote investment repackaging vehicle such as SPIRE" as its worked example — states that the look-through approach (Art. 84(2)) should be applied where:

the SPV issues an untranched, secured, limited-recourse obligation;
proceeds are invested in collateral assets (e.g. US Treasuries) representing market-risk exposures;
the SPV may enter a derivative to transform the asset's cash flows;
the SPV does no other business than holding assets, transforming cash flows and issuing notes; and
the note pays the combined cash flows of the collateral and the derivative.

What that means in practice

The insurer charges interest-rate, spread, currency and concentration SCR on the underlying bond and swap legs — not a single equity-type or unrated-structured-note charge. So a SPIRE note over an EU-sovereign or AA/AAA-rated government bond can keep that bond's favourable (often 0% spread-SCR) treatment, while the swap is captured for currency/rate risk. This is exactly why insurers use the platform for "zero-SCR yield" trades. Look-through relies on the manager/arranger providing position data (e.g. a Tripartite Template / TPT file). If the conditions above are not met — e.g. the note is tranched, actively managed, or the vehicle does other business — look-through does not apply and the note is treated under the rules for the relevant instrument type instead.

This is general regulatory information, not investment or legal advice; firms should confirm treatment with their own actuarial/regulatory teams for a specific note and reporting date.

Solvency II 2027 reform — does look-through still pay?

The 31 January 2027 Volatility Adjustment (VA) reform turns look-through from a no-brainer into a trade-off — for a foreign government bond + cross-currency swap wrapped as a single EUR note. Below is the €/notional P&L decomposed across the spread SCR, the swap counterparty/currency SCR, and the new VA/CSSR mechanism.

Worked example — held constant throughout. Per €100m notional: USD AA/AAA sovereign (own-currency rule → 0% spread SCR, spread duration ≈ 7) + USD-fixed → EUR-float cross-currency swap (collateralised; counterparty + currency SCR ≈ €1.0m combined). If instead held opaque and rated ~A at duration 7, the note's standalone spread charge under Art. 176 ≈ 7.0% + 0.7%×2 = 8.4% → €8.4m. EUR liabilities, BEL spread duration ≈ 8; risk-corrected spread (RCS) ≈ 50 bps.

The mechanism in one paragraph

Today the VA is a flat reference-portfolio add-on applied at a 65% application ratio — identical for everyone regardless of the assets actually held. So whether you look through the note or not, the VA you apply to liabilities is the same; the only thing that moves is the asset-side spread SCR. From 31 January 2027 the gross ratio rises to 85%, but it is now multiplied by an entity-specific Credit Spread Sensitivity Ratio (CSSR ∈ [0,1]), fed only by fixed-income spread-PVBP in the liability currency. That is what breaks the symmetry between the two treatments.

Current regime pre-31 Jan 2027

The applied VA is identical whichever way you report the note, so the decision is purely a capital one.

Component	Look-through	Opaque note
Spread SCR	0% (reach sovereign)	€8.4m
Counterparty + currency SCR (swap)	€1.0m	0
Applied VA	32.5 bps	32.5 bps — same
Total SCR	€1.0m	€8.4m

Benefit of look-through today ≈ €7.4m of SCR relief per €100m (~740 bps of notional; ~€0.44m/yr at a 6% cost of capital). It is purely a capital play: look-through pierces the wrapper to reach the 0% government-bond charge instead of a corporate-style spread charge. The VA is untouched, so there is no VA reason to prefer either treatment.

New regime from 31 Jan 2027

Look-through now reveals a USD-spread bond (wrong currency for the EUR VA bucket) plus a swap contributing zero spread-PVBP — so the position barely supports your EUR CSSR. Held opaque as a single EUR note, the full market value counts as EUR fixed income and lifts the CSSR. Look-through therefore acquires a new, hidden cost it never had before.

Component	Look-through	Opaque note
Spread SCR	0%	€8.4m
Counterparty + currency SCR	€1.0m	0
Applied VA (base 42.5 bps × CSSR)	CSSR drag → ~0 uplift	CSSR supported → +1–2 bp
VA own-funds value (BEL dur 8)	—	+€0.8–1.6m

What changed. Look-through's €7.4m SCR edge is now offset by a €0.8–1.6m VA give-up it didn't have before — the reform narrows the advantage by ~15–25%, and reverses it whenever the opaque note's standalone spread charge is small enough to be outweighed by the VA gain.

The advantage reverses when…

the wrapper is high-rated or guaranteed, so its spread charge shrinks toward 0 and look-through's SCR edge largely disappears; and/or
your VA-eligible BEL is large relative to this position, so the CSSR uplift is worth more than the marginal €/bp shown above.

Where it crosses over from 31 Jan 2027

Net economic advantage of look-through over the opaque note (€m PV per €100m), as the wrapper rating worsens left → right. Above the zero line, look-through still wins; below it, the structured note wins. The three lines are different sizes of VA-eligible liability book leaning on this position's CSSR contribution — the second lever alongside rating.

SCR relief is valued at a cost-of-capital PV burden (≈ 6% × asset life ≈ 0.4× the SCR amount, risk-margin logic); VA give-up is the own-funds value forgone by look-through's CSSR drag. Spread charges per Art. 176 at duration 7: AAA 5.5%, AA 6.7%, A 8.4%, BBB 15.5%. Illustrative — exact crossover depends on your CSSR, basis and book size.

The reading: with a small or medium VA book, look-through stays ahead across the whole rating scale — the 0% sovereign charge is simply too valuable to give up. Only with a large VA book does the opaque note win, and even then only for higher-rated wrappers (AAA–A), where the note's own spread charge is low enough that the VA gain dominates. That is the precise sense in which the reform "reverses" the decision.

Bottom line

The intuition holds in direction: post-2027 the structured-note treatment gains a VA advantage it never had, and look-through stops being free. But it is not a clean flip — it is a genuine breakeven between the wrapper's spread charge and the VA/CSSR uplift. The honest one-liner: the reform converts look-through from a no-brainer into a trade-off.

Load-bearing caveat. The whole opaque-note benefit rests on the note escaping mandatory Art. 84 look-through (which binds CIUs and fund-packaged investments, arguably not a debt repack) — and on the CSSR recognising the wrapper as EUR fixed income at full spread-PVBP. A national supervisor applying substance-over-form to a thin wrapper could collapse the benefit to the look-through column. Worth pre-clearing.

Illustrative figures using round assumptions to expose the structure of the P&L, not a calibrated valuation. Spread factors per Delegated Regulation Art. 176; VA mechanics per the 2027 review (Directive (EU) 2025/2 and Delegated Acts, applicable from 30 Jan 2027).

Who is potentially affected

Read as profiles, not allegations. SFCRs disclose how much an insurer relies on the VA and its solvency sensitivities, but not whether a given group runs foreign-bond + cross-currency repack notes with look-through. The names below are matched on the two levers that drive the chart — VA reliance (book size) and capital strategy — and are illustrative only.

Scenario A — look-through stays optimal (small/medium-book lines, always above zero)

Insurers who have discontinued the VA or barely use it: the opaque note's VA upside is ~zero, so nothing offsets look-through's capital edge — piercing to the 0% sovereign always wins. The 2024 disclosures name Allianz, Talanx/HDI, R+V and MAPFRE as having dropped the VA; add UL-heavy, strongly-capitalised groups with small guaranteed back-books.

Scenario B — structured note becomes newly attractive (large-book line dips below zero)

Insurers with a large VA-eligible guaranteed book and sizeable foreign-currency asset programmes swapped back to base. The CSSR uplift on a big EUR BEL then outweighs the spread charge given up on a high-rated wrapper.

Profile	Why they fit Scenario B	Illustrative names
Large traditional savings / annuity GA, heavy VA reliance	Big EUR BEL leaning on CSSR; every applied-VA bp is large in absolute terms	CNP Assurances, Crédit Agricole Assurances, Generali, Poste Vita, Ageas
Spread-driven annuity / run-off consolidators	Run large fixed-income & cross-currency books; intensely capital- and spread-optimised	Athora, Aegon, NN, ASR, Viridium / Monument

In between — the genuine breakeven cases

Moderate VA users — the disclosures list Generali, Aviva, VIG, Groupama, Legal & General as applying the VA — sit near the crossover, where the answer flips on the specific wrapper rating and their actual CSSR. These are the cases where intuition won't tell you which side of zero they land on, and a parametric run earns its keep.

Two clean live examples. Allianz dropping the VA is the clearest Scenario A — with no VA benefit to protect, its calculus is unchanged by the reform. Generali, still on the VA with a large general account, is the clearest Scenario B candidate.

Profile mapping drawn from 2024 SFCR disclosures of VA usage and book mix — see Sources (Solvency II Wire, Milliman, S&P Global). General regulatory information, not investment or legal advice.

Sources

Updating this page (incl. OpenFIGI lookups)

All content is driven by the SPIRE_DATA object at the top of this file's script. To add a series, append an object to SPIRE_DATA.series and re-open the page. New dealers / prospectuses go in their arrays.

Resolve an ISIN ⇄ FIGI and instrument metadata with your key (run locally, where OPENFIGI_API_KEY is set):

curl -s https://api.openfigi.com/v3/mapping \
  -H "Content-Type: application/json" \
  -H "X-OPENFIGI-APIKEY: $OPENFIGI_API_KEY" \
  -d '[{"idType":"ID_ISIN","idValue":"XS2936521710"}]'

To enumerate the full live register, pull SPIRE's securities from LuxSE and Euronext Dublin, or read the per-series schedule in SPIRE's audited financial statements.

SPIRE SA — Single Platform Investment Repackaging Entity