Ryan LLC, et al. v. FTC
Court: U.S. District Court (N.D. Texas) Amicus Issue: Whether the FTC exceeded its statutory authority under the FTC Act by…
SIFMA, the American Bankers Association (ABA), the ABA Securities Association, and The Financial Services Roundtable (FSR) provide comments to the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission (SEC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Agency (FHFA), and the U.S. Department of Housing and Urban Development (HUD) (collectively, the Agencies) on the Agencies’ proposed rule for credit risk retention.
Although the Associations continue to believe that in important ways the re-proposed rules should be revised to address the positions we set forth in this letter, they appreciate and support many aspects of the re-proposed rules. In particular, the Associations strongly support the following features of the re-proposed rules:
In light of this, this letter focuses on recommendations that Associations believe would improve the re-proposed rules, while allowing asset securitization markets to continue to provide access to cost-effective credit to individuals and companies, and important capital markets investment alternatives for investors.
Court: U.S. District Court (N.D. Texas) Amicus Issue: Whether the FTC exceeded its statutory authority under the FTC Act by…
SIFMA, The American Bankers Association (ABA), Bank Policy Institute (BPI), and the Financial Services Forum (FSF), provided comments to the…
Court: Delaware Supreme Court Amicus Issue: Whether the Delaware Supreme Court’s holding in Cantor Fitzgerald precludes reviewing forfeiture-for-competition provisions for…
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