The recently launched Freedom Park conduit makes use of just about every bell and whistle available to the ABCP market. According to Promontory Group, the parent company of Freedom's administrator, the vehicle is structured to address today's most notable challenges, including changing accounting rules, disappearing liquidity and evolving regulatory capital adequacy guidelines.

For one, Freedom operates without direct bank liquidity support, and, being an independent finance company, Promontory is probably less concerned with consolidation.

Like other recent vehicles, Freedom mitigates bank liquidity support partially through extendible paper. All of Freedom's assets (at least initially) must be triple-A rated and guaranteed by one of the monolines. If, during an extension period, Freedom is unable to liquidate the corresponding assets, Freedom can exercise a put option with a separate vehicle, Blue Moon Funding, which in turn issues MTNs to finance the purchase. To the extent that Blue Moon is unable to sell the MTNs, Bank of America, through a second put, is obligated to purchase the MTNs, so long as the guarantor of the assets purchased by Blue Moon is not in bankruptcy

Also during an extension period, sub-administrator JPMorgan Chase has the option to purchase the assets outright.

Freedom is administered by Promontory Asset Finance Co., a subsidiary of Promontory Group created in 2003 with a next-generation conduit in mind. Promontory's team includes Jeff Bardo, chief operating officer, and Duncan Hennes, chief executive officer. Both have roots at Bankers Trust. Hennes was most recently the CEO of Sorros Fund Management. Also on board are former conduit pros from ING, John Costa, Robert Novick,and Herold Gartner. The three joined Promontory around April last year.

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