The Financial Accounting Standards Board recently offered a potential loophole appendix to FIN 46 for some in securitization markets with the proposal of FIN 46 (R)-b, the staff position for which may soon be released for a 45-day comment period. FIN 46 (R)-b, offering amnesty from consolidation for parties that do not have an explicit relationship with a particular variable interest entity, will be run past a pair of industry spokesgroups, prior to being released for 45-day comment, which is expected within weeks.

Any changes would primarily impact the privately held unit interests of larger entities that also have relationships with the variable interest entity (VIE) of the parent.

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