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 The 
group includes the Association for Financial Markets in Europe (AFME), 
the Dutch Securitisation Association, the European Banking Federation 
(EBF), the International Association of Credit Portfolio Managers 
(IACPM), Leaseurope, Eurofinas, Paris EUROPLACE, PCS and True Sale 
International (TSI).
The letter calls for urgent action as it highlights how securitisation 
volumes in Europe have continued to decline in 2022, in sharp contrast 
to the growth seen in other markets in recent years. The United States, 
for example, recorded its highest ever issuance levels in 2020 and again
 in 2021.
It is also a critical moment for the European securitisation market as 
key regulatory workstreams are underway which could contribute to the 
recovery of the market or exacerbate current regulatory imbalances. For 
example, targeted measures in the prudential requirements for banks 
under CRR3, and insurers under Solvency 2, together with a well-designed
 EU Green Bond Standard, would be important steps towards a better 
functioning market. The organisations are therefore calling on EU 
legislators to use these discussions to introduce immediate adjustments 
to securitisation-related calibrations  and concrete mandates for more 
risk sensitive revisions to be undertaken as a subsequent step. There 
are also critical technical standards under preparation which could 
negatively impact the market if further disproportionate requirements 
are introduced.
The joint Association leaders write in the letter: “The absence of a
 well-functioning securitisation market represents a strategic loss to 
the European financial system. It is undermining the competitiveness of 
European financial institutions and limiting their ability to recycle 
capital to support new financing. It has encouraged institutional 
investors to shift towards other products that do not offer the same 
advantages in terms of protection, transparency and liquidity.”
“At the heart of the problem is a disconnect between the Commission’s 
vision for securitisation in Europe – a tool making a significant 
contribution to a well-functioning financial system that efficiently 
finances the real economy – and aspects of the regulatory framework 
which remain miscalibrated and, in practice, disincentivise issuance and
 investment in securitisations, thus holding back the tool’s potential 
to support the economy.”
 
The full letter can be found here