The Bond Market Association (TBMA)* provides comments to the agencies that make up the Federal Financial Institutions Examination Council (FFEIC) on proposals to revise risk-based capital standards to address the regulatory capital treatment of recourse obligations and direct credit substitutes that expose banking organizations to credit risk.   In many respects, TBMA regards the current proposals as a material advancement beyond the FFIEC 1994 proposals, and a significant improvement over the status quo.  TBMA offers several general comments concerning what we believe to be the appropriate evolution and further development of regulatory risk-based capital requirements for asset securitizations.

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