In commentary, the European Securitisation Forum targeted generalization and overly broad definitions/criteria as some of the more problematic issues associated with the securitization section of the Bank of International Settlements Proposal, the international guidelines for risk based capital weighting.

Specifically, while the ESF welcomes risk-based capital treatment, the Forum "strongly believes that the use of a greater number of credit buckets than the five proposed... is called for in order to ensure a closer correlation to the differing default probabilities at different rating levels."

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