At this point, it's clear as day how strongly the U.S. securitization industry opposes the amendments to FAS 140, as proposed by the Financial Accounting Standards Board (FASB).
Save the lone letter of praise from Sen. Carl Levin (D, Mich.) submitted June 30, the subsequent 49 submissions posted on the FASB Web site over the past few days urge caution at the very least, warn of "unintended consequences," and even beg the Board to seriously reconsider the value and costs involved in further changing the way structures are documented and accounted for by the several parties to common securitizations, which do not even remotely resemble the Enron-related shady dealings the Board is intent on preventing (other than sharing with Enron a few catch phrases). To see all 50 letters, click here.
Cited from Fannie Mae's letter:
"If consolidation were required on March 31, 2003 for Fannie Mae-guaranteed MBS held by other investors, Fannie Mae would have recorded an asset and liability gross up of approximately $1.108 trillion. Our total assets would increase from $913 billion to approximately $2.021 trillion even though we do no own and have not control over the assets underlying the MBS. This balance sheet gross up would substantially increase Fannie Mae's minimum capital requirements."