SIFMA and The Financial Services Roundtable (FSR) provide comments to the Securities and Exchange Commission (SEC) on CFTC’s February 25, 2014, staff memorandum (the Memorandum), suggesting that issuers might use their websites to disseminate asset-level data and other offering information to investors and potential investors, as required under the Commission’s proposed offering, disclosure, and reporting requirements for asset-backed securities (ABS).

Although the Associations’ members generally support the disclosure of asset-level data with respect to some ABS asset classes (File Number S7-08-10), they urge the SEC to abandon the flawed disclosure mechanism suggested in the Memorandum, which would expose both consumers and issuers to unwarranted risks and liabilities. Instead, the Commission should re-propose the ABS Releases in order to accommodate a more detailed and comprehensive reconsideration of the difficult technical, legal, and public policy concerns raised by asset-level disclosure.