Requesting an Extension of Comments on Credit Risk Retention

SIFMA, the Association for Financial Markets in Europe (AFME) , and the Structured Finance Industry Group (SFIG) submit comments to the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development (HUD), the Federal Housing Finance Agency (FHFA), the Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) requesting a 40-day extension of the comment period for the Notice of Proposed Rulemaking on Credit Risk Retention, SEC (Release No. 34-64603; File No. S7-14-11); FDIC (RIN 3064-AD74); OCC (Docket No. OCC-2011-0002); FRB (Docket No. 2011-1411); FHFA (RIN 2590-AA43); HUD (RIN 2501-AD53); and support the same request filed by the Loan Syndications and Trading Association (LSTA).

The Associations agree with and support LSTA’s concerns regarding the need for more time to consider the significant revisions to the proposed risk retention rule as it relates to collateralized loan obligations (CLOs). In order to develop thoughtful comments on proposed framework, market participants will require significant time to consider how it is similar to, and distinct from, current market practice. In turn, market participants will need to analyze how meaningful the deviations are, and what the consequence of those deviations will be for the ability of the CLO markets to fund extensions of credit.