The Securities Industry Association (SIA)*, The Bond Market Association (TBMA)* and the International Swaps and Derivatives Association (ISDA) provide comments to the Office of the Comptroller of the Currency (OCC) in the U.S. Department of Treasury (Treasury), the Office of Thrift Supervision (OTS), the Board of Governors of the Federal Reserve System (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Securities and Exchange Commission (SEC) on the revised interagency statement on sound practices concerning elevated risk complex structured finance activities. The Associations support the improvements in the revision and requests the Agencies reconsider any requirement that financial institutions document the “reasons” for their approval, conditional approval or disapproval of an elevated risk complex structured finance transactions (CSFT).

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.