All the rating agencies have recently issued warnings about or downgraded re-securitizations, known as re-REMICs, and while those deals issued over the last few years appear hardy enough to withstand another housing downturn, their resemblance to infamous CDOs raises concerns.

Moody's Investors Service issued a special report Jan. 18 describing its concerns about RMBS re-REMICs, saying, "During the past two years, we rated less than 1% of the approximately 5,500 RMBS re-securitizations that were rated and issued in the market." That amounted to just three ratings in 2010 and 38 the year before. Last June, Fitch Ratings detailed the types of re-REMICs for which it declines to issue ratings, including those backed by subprime or Alt-A collateral, and noting, "Fitch currently rates less than 10% of re-REMIC transactions it has been presented to review."

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