Joint Proposed Rules Relating to Credit Risk Retention

SIFMA provides comments to the U.S. Department of the Treasury, Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC), the Federal Housing Finance Agency (FHFA), and the U.S. Department of Housing and Urban Development (HUD) on jointly proposed rules relating to credit risk retention.  The jointly proposed rules are intended to implement the requirements of section 941(b) of the Dodd–Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). SIFMA requests clarification on the jointly proposed rules, in particular, the key concept of “par value,” which is used in the proposed rules, but is not defined.