As executive director of the American Securitization Forum, I am exited about the membership participation across the spectrum of all the committees and subcommittees of the ASF. The most urgent matter for the ASF is the SPE consolidation project, with the comment period ending Aug. 30. While the ASF supports the goal of transparency in accounting we do not think the methods proposed in the exposure draft contribute to this goal of transparency. The following outlines what we have expressed to regulators regarding the topics currently under debate.

Dwight Jenkins, Esq.

Executive Director

Regulatory Bodies approached:

Board of Governors of the Federal Reserve

Office of the Comptroller of the Currency

Federal Deposit Insurance Corporation

Office of Thrift Supervision

Views expressed on economic and market impact of consolidation

It is not necessary to consolidate SPE to achieve transparency.

Consolidation of Securitization SPE often produces more rather than less misleading financial statements, and, accordingly a new standard should accommodate the necessary nuances rather that overly-strict rules that exacerbate rather than ameliorate the problem.

Consolidation is problematic for CDO Managers and ABCP Conduit Sponsors/Administrators.

Consolidation would increase pricing, decrease volume of capital available, reduce the availability of quality investments, cause diminished liquidity and ultimately cause a drag on the economy.

Effect on banks would be a decrease in regulatory capital and cause CFO to decrease ABCP vehicle activity, decrease profitability, cause disintermediation due to loss of a bank product line and decrease liquidity.

Decreased transparency due to analysts having to back out the newly inserted CDO and Conduit numbers from balance sheets to be able to compare banks.

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