Invitation to Comment— Recognition of Intangibles
SIFMA comments to the Financial Accounting Standards Board (FASB) on the Invitation to Comment— Recognition of Intangibles (the “ITC”). SIFMA…
SIFMA and several other trade associations submitted a statement of principles related to homeowner’s association (HOA) super liens. The letter was submitted to The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System.
The letter highlights the “safety and soundness” issue concerning the risks posed to banks, as originators and/or servicers, as whole-loan investors and as securitization sponsors and/or investors, in residential mortgage loans and/or residential mortgage-backed securities (“RMBS”), by certain state law provisions that allow HOA liens, in certain cases, to achieve a “super-priority” status that permits the extinguishment of a prior perfected and recorded first mortgage lien on the related property, sometimes without prior notice to the lienholder and often at a small percentage of the first mortgage balance.
SIFMA comments to the Financial Accounting Standards Board (FASB) on the Invitation to Comment— Recognition of Intangibles (the “ITC”). SIFMA…
SIFMA, The American Bankers Association (ABA), Bank Policy Institute (BPI), Independent Community Bankers of America (ICBA), and Institute of International…
SIFMA, SIFMA AMG, and the International Swaps and Derivatives Association, Inc. (ISDA) provided comments in response to the U.S. Commodity…