On August 30 the IIF submitted a response to the FSB consultative report: Evaluation of the Effects of the G20 Financial Regulatory Reforms on Securitization. We commend the FSB for the work it is doing in this important area. However, while we understand the mandate of the FSB is on financial stability, we believe that the almost exclusive focus on stability narrows the analysis and limits the opportunity to appropriately consider numerous other factors that impact securitization activity and markets. We consider that the report does not adequately take into account broader factors which also contribute to financial stability, including market depth, liquidity and the broader pool of financing options and tools. We highlight in our submission important issues impacting and constraining the securitization market, and we recommend that the FSB continue more detailed work on securitization to analyze these factors and issues, and crucially that the FSB encourages the BCBS to undertake work to analyze and review the prudential factors that are also constraining securitization activities and markets.