The Federal Deposit Insurance Corp. (FDIC) received 31 comment letters regarding the advance notice of proposed rulemaking (ANPR) on the safe harbor. The comment period ended yesterday.
In this ANPR released on Dec. 15, the FDIC solicited comments from the industry regarding proposed amendments to the legal isolation safe harbor for off-balance sheet securitizations created after March 31.
Given the amount of time between now and the end of March to consider the comments on this ANPR, the interim rule to extend the securitization safe harbor announced in November last year will most likely be extended beyond the March 31 end date, FDIC's Deputy to the Chariman for Policy Michael Krimminger said at the recent American Securitization Forum (ASF) conference.
The firms and individuals that submitted comment are the following:
Graham Fisher & Co.
TYI, Richard Field
Timothy Shapiro
Consumers Union, Norma Garcia
Lisa Capuano
Mortgage Bankers Association, John Courson
CANICCOR, John Lind
Financial Services Roundtable, Rich Whiting
ASF, Tom Deutsch
Risk Management Association, Edward DeMarco
Fitch Ratings, Charles Brown
Alberto Zonca
Commerical Mortgage Securities Association, Dottie Cunningham
Association of Financial Guaranty Insurers, Bruce Stern
Wells Fargo, David Maskowitz
K&L Gates
Moody's Investor Service, Fariza Zarin
Orrick, Herrington & Sutcliffe, Douglas Madsen
Discover Financial Services, Roy Guthrie
ABA Securities Association, Cristeena Naser
MetLife, Charles Scully
Kutak Rock
National Consumer Law Center
CalPERS, Anne Simpson
SIFMA, Randolph Snook
Center for Responsible Lending, Julia Gordon
Bank of America, Gregory Baer
Cadwalader, Wickersham & Taft, Julius Loeser
JPMorgan, Adam Gilbert
Capital One, Stephen Linehan
Redwood Trust, George Bull
