SIFMA provides comments to the Department of the Treasury, Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation; the Securities and Exchange Commission (SEC); and the Federal Housing Finance Agency and the Department of Housing and Urban Development on the Agencies’ jointly proposed rules to implement the requirements of section 941(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which is codified as new Section 15G of the Securities Exchange Act of 1934, as amended.

The letter reflects the initial comments of our originator, sponsor and dealer members on the proposed rules. We expect to provide additional, detailed comments on certain aspects of the proposed rules prior to the close of the comment period. For the reasons discussed below, we believe that, notwithstanding the Agencies’ decision to extend the comment period until August 1, 2011, it is important that the proposed rules be reconsidered and republished in proposed form for further public comment before final risk retention rules are adopted.

Although we believe that in important ways the proposed rules should be revised, we recognize that credit risk retention has been mandated by statute, and we appreciate and support many aspects of the proposed rules. We have endeavored to offer thoughtful comments and constructive recommendations for improvement of the proposed rules.

See also the letter filed by the Asset Management Group (AMG) of SIFMA.