The American Securitization Forum (ASF) reiterated its support for retention requirements tailored to each major asset class and that offer flexibility for the long term, the trade group said in a release today.

The ASF did this via a series of letters submitted to joint regulators that are in charge of implementing risk retention requirements for ABS under the Dodd-Frank Act,

The organization detailed the different forms of retention and the type of asset (specifically, autos, credit card, RMBS, student loans, and the proposed exemption for ABCP) to which each would be most appropriately applied.

The association’s credit card ABS risk retention comment letter submitted today stated the views of the ASF's credit card ABS issuer and investor members on the types of mechanisms that should be available within credit card securitizations to comply with the risk retention requirements. This includes a "seller’s interest" risk retention and a "horizontal slice" risk retention.

Similary, its student loan ABS risk retention comment letter was submitted today. It also contains the views of student loan ABS issuer and investor members in terms of two aspects. The first is FFELP loan pools for which an exemption to the risk retention requirements is appropriate and the second is the "horizontal slice" risk retention, which is meant for private student loan securitizers to comply with the risk retention requirements.

ASF’s auto ABS risk retention comment letter was submitted on Nov. 22 containing views from its auto ABS issuer and investor members. This letter pertains to the types of mechanisms that should be available within auto ABS to comply with the risk retention requirements and ertain "qualified" auto pools of assets that would require an adjustment to such requirements.

ASF’s ABCP risk retention comment letter was submitted yesterday. This focuses on the ASF's concerns regarding the possible application of the credit risk retention obligations to the following: certain ABCP conduits; their sponsors and credit and liquidity support providers; as well as to ABCP customers and conduit sponsors that finance assets via such ABCP conduits where such financings meet the Dodd-Frank Act's definition of ABS.

ASF’s RMBS risk retention comment letter was submitted on Nov. 12. It also sets forth views of the group's RMBS issuer and investor members about the appropriate forms of risk retention and the qualified residential mortgage exemption.

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