A letter sent jointly by AFME, ICMA, and various pan-European, Dutch and German trade bodies repeats the points you have read in this blog about the continuing very uneven playing field for securitisation compared to other fixed income instruments, and especially covered bonds: for Solvency II, the risk factors remain too high for non-senior tranches of STS securitisations, and for all non-STS securitisations; and for the Liquidity Coverage Ratio, senior tranches of STS securitisations and fully supported ABCP programmes should be promoted under the LCR. AFME comments: “The revised calibration should make it attractive for insurers to invest in European securitisations, and level the playing field with whole loan investment so as not to incentivise investment in the same underlying assets in an un-securitised and illiquid format”, noting that the door is now closed on Solvency 2, but the debate on the LCR remains open