The Bond Market Association (TBMA)* provides additional comments to the State of New York Banking Department (Department) on the Department’s revised proposal encouraging the adoption by underwriters of recommended Due Diligence Best Practices in order to combat abusive practices in the subprime market place.  TBMA notes that revised draft reflects several changes responding in part to TBMA’s first set of comments on August 1, 2000.  TBMA offers additional observations and recommendations on the remaining open issues that cause concern.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.