Proposed Guarantee Program for Troubled Assets

SIFMA and the American Securitization Forum (ASF) provide comments to the U.S. Department of Treasury on the development of a program to guarantee the timely payment of principal of, and interest on, troubled assets originated or issued prior to March 14, 2008, as authorized by Section 102 of the Emergency Economic Stabilization Act of 2008 (ESSA). SIFMA cautions that: 1) the potential liquidity and stability that could be provided by the Guarantee Program must be weighed against the liquidity and stability that could be provided by the purchase program; 2) the duration and complexity of a Guarantee Program must be weighted against the duration and complexity of the purchase program; and 3) the risk to taxpayers under a Guarantee Program must be weighed against the risk to taxpayers under the purchase program.