SEC Updates Compliance and Disclosure Interpretations for Legacy Deals

On September 16, the SEC  released its updated compliance and disclosure interpretations for the rules adopted under Regulation AB, the Securities Act and the Exchange Act. Among others, the updated interpretation clarified that securitizations for which offers are made prior to November 23, 2016 are not required to provide asset-level disclosures in the prospectus or on an ongoing basis with each Form 10-D.  Compliance and Disclosure Interpretation.