Structured Finance Association
Structured Finance AssociationOpposeTrade association
Summary: The Structured Finance Association (SFA) opposes several provisions in the proposed rules, specifically the addition of the word "solely" to the definitions of traditional and synthetic securitization, which they argue creates unnecessary capital burdens and violates the Administrative Procedure Act. They also request clarifications on the BCC 13-2 interpretive framework and argue against a 100% risk weight floor for certain senior resecuritizations.
See attached file(s)