The Bond Market Association (TBMA)* provide comments to the State of New York Banking Department (the Department) on the proposal of the Department, which encourages the adoption by underwriters of Due Diligence Best Practices in order to combat abusive lending practices.  TBMA does not believe that adoption or endorsement of the specific best practices by the Department as they would apply to underwriters of mortgage-backed securities would be an effective or desirable policy response to such lending practices in the subprime mortgage origination markets.

TBMA provides supplemental comments to the Department on November 14, 2000.

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