ABA

SIFMA Sends Comment Letters to FHFA on Credit Risk Transfer

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SIFMA, along with the Association of Mortgage Investors and the National Association of Real Estate Investment Trusts, and separately along with the ABA, AMI, HPC, MBA, and SFIG, submitted comment letters to the FHFA in response to the FHFA request for comments on the GSEs credit risk transfer programs, particularly with respect to exploration of more “front end” risk transfer options that share risk with the private sector before, or concurrently with, the purchase of loans by the GSEs. SIFMA, AMI, NAREIT Comment Letter Joint Trades Comment Letter.

LSTA and ABA Provide Comments to Proposed Leveraged Lending Guidelines

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On March 30, the Fed, OCC and FDIC issued Proposed Guidance on Leveraged Lending. On June 8, 2012, the LSTA, together with the American Bankers Association (ABA), responded with comments to such guidelines. The comments suggested that more modest changes to the current leveraged finance guidance would allow banks to continue to safely manage the risks of leveraged finance without imposing undue burdens. Generally, the comments noted the costs of implementing the guidelines in comparison to the potential benefits and emphasized that the guidelines are only recommendations that need to remain flexible enough for implementation by a variety of lending institutions across the broad spectrum of leveraged lending transactions. Proposed Guidance. LSTA and ABA Comments.