Asset-Backed Securities Regulation - Comment Letter - BNY Mellon - July 30, 2010

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Dodd-Frank Timeline, Shelf Eligibility Requirements for Asset-Backed Securities
Proposal Date Comment File Reopened New Comment Deadline
August 5, 2011 February 25, 2014 March 28, 2014

Asset-Backed Securities
July 30, 2010

In the comment letter, BNY Mellon favors the portion of the proposed rule regarding analytic disclosure, believing it would:

  • "enhance market transparency;
  • shift the focus of risk disclosure from the few scenarios selected by an issuer to the many sought by investors;
  • protect investors' privacy by allowing them to analyze each transaction themselves, without disclosing the nature of that analysis to issuers, underwriters or other investors;
  • empower investors to analyze transactions throughout each transaction's life cycle, allowing lessons learned from existing transactions to be applied to new transactions;
  • promote a dialogue between issuers, underwriters and investors that is open, complete and fair;
  • broaden the general understanding of asset-backed securities;
  • enable alternative critical points of view, in addition to the existing credit-rating agencies;
  • support any effort to evaluate and monitor market risk; and
  • reduce operational errors."

Before finalizing the rule, BNY Mellon recommends that the Commission:

  • "clarify technical architecture;
  • establish rights and responsibilities for intellectual property; and
  • promote interoperability, usability and open access."



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