SIFMA and the Loan Syndication and Trading Association (LSTA) provide comments to the U.S. Department of Treasury and the Internal Revenue Service (IRS) on proposed technical corrections to the limited life debt investment entity (LLDIE) definition in the final regulations issued to implement the provisions of the Foreign Account Tax Compliance Act (FATCA). The groups believe the LLDIE definition, as written, has certain requirements that cannot be satisfied by most collateralized loan obligations (CLO’s) or by similar special purpose investment vehicles that issue primary debt securities with a fixed maximum return.