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HUDRulemakingHUD-2011-0056

Credit Risk Retention

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American Bankers Association filings
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American Bankers Association filed 1 comment on this docket between Aug 2, 2011 and Aug 2, 2011. 80 other organizations filed here. The comment window closed 5475d ago.

What American Bankers Association filed (1)

Aug 2, 2011· Comment Submitted by Robert Davis, American Bankers Association (ABA) and the ABA Securities Association (ABASA)· HUD-2011-0056-0268

The American Bankers Association (ABA) and the ABA Securities Association (ABASA) are pleased to respond to the request for comment by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (the "Banking Agencies"), the Securities and Exchange Commission (the "SEC" or the "Commission"), and the Federal Housing Finance Agency and the Department of Housing and Urban Development (collectively, the "Agencies") on the Agencies' joint proposal to implement the requirements of section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act or DFA). Section 941 generally requires securitizers of asset-backed securities (ABS) to retain an economic interest in a portion of the credit risk of those transactions. It further directs the Agencies to craft exceptions to the risk retention requirements that incent securitization participants to originate soundly underwritten assets and align the interests of participants with investors, consistent with improving access to credit on reasonable terms. ABA represents both small and large banks that participate actively in the securitization market both as originators and securitization issuers. ABASA represents the largest banks that are active in capital markets. Our members are involved in all aspects of securitization transactions, from origination, much of which is performed by small banks, to sponsoring and issuing AB

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Co-filers (80)

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