Structured Finance Association

Structured Finance AssociationOpposeTrade association
Summary: The Structured Finance Association (SFA) opposes several provisions in the proposed rules, particularly the addition of the word "solely" to the definitions of traditional and synthetic securitization, arguing it creates arbitrary capital requirements and ignores economic substance. They also request clarifications on relying on existing interpretive frameworks for investment firm exposures and advocate for several specific modifications to risk-weighting and parameter calculations.
See attached file(s)

View on Regulations.gov