The American Securitization Forum has submitted a letter to federal banking regulators requesting the near-term announcement of a six-month moratorium on any regulatory capital rule changes related to the implementation of accounting standards FAS 166 and 167, and the proposed elimination of the option for ABCP conduit sponsors to disregard consolidation of conduits for risk-based capital purposes. 

The ASF requests the announcement of a moratorium as soon as practical, supported by the rationale that by the time final rules are promulgated banks will likely have no choice but to begin the process of capital raising and reallocation of resources based on assumptions developed from the conservative approach that the proposed rules take, regardless of any changes that might be included in the final rules. 

This, they said, could have significant, negative, and possibly unnecessary consequences on both the banking system and credit availability more generally.  If regulators are unwilling to grant the moratorium, the ASF requests that they announce a phase-in period of at least four quarters.  

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