SIFMA provides comments to the Securities and Exchange Commission (SEC) on the re-proposal of shelf eligibility conditions for asset-backed securities, Release Nos. 33-9117; 34-61858; File No. S7-08-10.  The re-proposing release revises and re-proposes certain rules that originally were proposed in April 2010 in Release Nos. 33-9117, 34-61858, Asset-Backed Securities; Proposed Rule (April 2010 Proposing Release), in light of the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and comments received in response to the April 2010 Proposing Release.

While we believe that modification of some of the re-proposals is appropriate, we have endeavored to offer constructive recommendations that will make the markets for asset-backed securities (“ABS”) and other structured finance products more transparent, more stable and more efficient. We also have endeavored to provide thoughtful and useful responses to many of the Commission’s additional requests for comment.