Premium Capture Provisions for Risk Retention Proposals

SIFMA, as part of a coalition, provides comments to the Board of Governors of the Federal Reserve, the Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC), the U.S. Department of Treasury, the U.S. Department of Housing and Urban Development (HUD), and the Federal Housing Finance Agency (FHFA) opposing the premium capture cash reserve account (PCCRA) provision of the proposed rule on credit risk retention under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The coalition notes that if included into the final rule, PCCRA would severely curtail the issuance of non‐Agency residential mortgage‐backed securities (RMBS) and commercial mortgage‐backed securities (CMBS).  In addition, the coalition shares concerns that the actual effect of the PCCRA has much broader and harmful consequences to consumers, investors and other participants in private securitization markets.