American Bankers Association
OCCRulemakingOCC-2013-0010

Credit Risk Retention

RIN
Last modified
May 5, 2017
Comment window
closed 4654d ago
American Bankers Association filings
1

Activity

American Bankers Association filed 1 comment on this docket between Nov 4, 2013 and Nov 4, 2013. 64 other organizations filed here. The comment window closed 4654d ago.

What American Bankers Association filed (1)

Nov 4, 2013· OCC-2013-0010-0159

The American Bankers Association (ABA) is pleased to submit the following comments with regard to the Qualified Residential Mortgage (QRM) provisions included in the above referenced proposed rule. ABA is also a member of the Coalition for Sensible Housing Policy and is joining in the comments submitted by that Coalition and has joined with the Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Roundtable (FSR) to comment on QRM and a number of other credit risk retention issues. In addition to the comments filed by the Coalition for Sensible Housing Policy and jointly with SIFMA and FSR, ABA wishes to highlight the specific points in this letter with regard to QRM.

Abstract

The OCC, Board, FDIC, Commission, FHFA, and HUD (the agencies) are seeking comment on a joint proposed rule (the proposed rule, or the proposal) to revise the proposed rule the agencies published in the Federal Register on April 29, 2011, and to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934 (15. U.S.C. 78o-11), as added by section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Section 15G generally requires the securitizer of asset-backed securities to retain not less than 5 percent of the credit risk of the assets collateralizing the asset-backed securities. Section 15G includes a variety of exemptions from these requirements, including an exemption for asset-backed securities that are collateralized exclusively by residential mortgages that qualify as ``qualified residential mortgages,'' as such term is defined by the agencies by rule.

View on regulations.gov →