SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s proposed rulemaking on the definition of a “mortgage-related security” under section 939(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), Release No. 34–64352; File No. S7–15–11; RIN 3235–AL14.

SIFMA argues that the SEC’s proposed construct would not create the clear, objective, and easy to apply standards that are needed for this issue.  SIFMA recommends some potential alternative approaches, and urges the SEC to continue to consider this issue.