Earlier today the American Securitization Forum, in conjunction with the Bond Market Association, submitted its joint comment letter to the Financial Accounting Standards Board concerning the Board’s proposed amendment to FAS 140.

According to the two industry groups, FASB’s amendment to 140 has two main goals: to further restrict the kinds of support that transferors and their affiliates and agents can provide to QSPEs, and to prevent certain entities that can reissue beneficial interests from operating as QSPEs in response to the adoption of FIN 46.

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