suspension of the reporting obligations

SEC No Action Letter and Proposed Rule for Section 15(d)

On January 6, the SEC issued a no-action letter confirming that it would not recommend enforcement action if an ABS issuer continues to determine its reporting requirements for existing transactions based on the standards set forth in Section 15(d) of the Exchange Act prior to the enactment of the Dodd-Frank Act, if certain conditions are satisfied. This no-action relief applies to any issuer which had suspended its reporting requirements for outstanding ABS prior to enactment of the Dodd-Frank Act. Also on January 6, the SEC proposed a rule to permit suspension of the reporting obligations for ABS issuers when there are no longer ABS of a class sold in a registered transaction held by non-affiliates of the depositor and to amend rules relating to the Exchange Act reporting obligations of ABS issuers in light of these statutory changes. Comments must be received by February 7. SEC No Action Letter. Proposed Rule.