The Structured Finance Committee of The Association of the Bar of the City of New York submitted a comment letter last week regarding proposed amendments to a Financial Accounting Standards Board rule on transfers of financial assets. The comment letter, the first from the newly formed committee, addresses proposed amendments to FASB's Statement of Financial Accounting Standards No. 140.

The rule, which was issued in September 2000 to address accounting for transfers and servicing of receivables and deals, governs the accounting for most securitizations. The rule specifically deals with whether certain transfers should be treated as sales or loans for accounting purposes and whether the debt of transferees must be included in the transferor's consolidated financial statements.

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