By Nichol Bakalar, vice president, asset-backed research strategist, and John Tierney, director of structured credit research, Deutsche Bank.For the third time in six years, the Federal Financial Institutions Examination Council1 (FFIEC) is publishing in the Federal Register a proposal to alter current risk based capital (RBC) requirements for banking organizations. We focus on aspects of the proposal that address securitization, including recourse obligations (e.g., retained interests and residuals), direct credit substitutes (e.g., standby letters of credit), and revolving transactions.

Timing is Still Uncertain

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