Implementation of the Dodd-Frank Act Relating to Conflicts of Interest

SIFMA provides comments to the Securities and Exchange Commission (SEC) on implementation of Section 621(Conflicts of Interest) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).  The SEC staff requested comments regarding potential conflicts of interest occurring in securitizations that should not be prohibited under Section 621 of the Dodd-Frank Act. In drafting rules to carry out the intent of Section 621, SIFMA believes the SEC should consider the primary motivation behind securitization and recognize that securitizations by their nature require various transaction participants to assume role and perform different functions as a part of a securitization transaction.