A handful of comment letters surfaced last week addressing the Financial Accounting Standard Board's controversial proposed amendment to FAS 140. The Exposure Draft has drawn heated responses from the securitization industry. The industry warns that even the most typical and fluid transactions, such as certain Agency mortgage-backed securities, which aren't structured through SPEs, could fail to comply with the new standard, should the final resembles the draft.

As for the ABS/CMBS side, where QSPEs make up the bulk of the term market, the American Securitiza- tion Forum and the Bond Market Association state in a letter submitted jointly, "[I]f the Exposure Draft is given its broadest reading, we doubt whether any current qualifying special-purpose entity would qualify under the proposed new standards."

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