Following the joint ASF/BMA comment letter sent to the Financial Accounting Standards Board this week, an additional 13 respondants sent comment letters to the  this morning to the regulatory board. Not surprisingly, respondants included some of the biggest ABS issuers, underwriters and law firms. The list of new respondants is as follows:

Kaye Scholer Llp, U.S. Bancorp, Nysscpa, Mayer, Brown, Rowe & Maw, Institute Of Management Accountants, MBNA America Bank, N.A, Merrill Lynch, JP Morgan Chase, Capital One Financial Corporation, First Horizon Home Loans, Commercial Mortgage Securities Association, American Financial Services Association, SLM Corporation, Credit Suisse Group, Frederick L. Feldkamp and The Asset Managers Forum

In his comment letter, MBNA America Bank Executive Vice Chairman Vernon H.C. Wright summs the common opinion: "[W]e believe that the Board's approach for achieving its stated objectives will have the unintended consequence of disqualifying many QSPEs where control has been effectively surrendered  and where legal isolation has been achieved under the original FASB statement No. 140 requirements adopted in 2001. We do not think that the changes proposed in the exposure draft are necessary in order for the Board to achieve its goals. In its current form, the amendment will have impacts that are well beyond what is necessary to achieve the Boards stated objectives and which  in many ways contradict the principals underlying FAS 140 and FASB statement No. 125."

To view all 23 comment letters, click here



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