Relief to Address Legacy Structured Finance Transactions

SIFMA and the American Securitization Forum (ASF) provide comments to the Commodity Futures Trading Commission (CFTC) requesting for relief to address “legacy” structured finance transactions.  The groups submit, for purposes of discussion, a draft exemptive order to fulfill this request. The groups believe there are factors that distinguish these financings from those done on a prospective basis that lessen the CFTC’s regulatory interests and justify their being granted regulatory relief on a broader basis.