Asset-Backed Securities Regulation - Comment Letter - Investment Company Institute - November 15, 2010

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Dodd-Frank Timeline, Issuer Review of Assets in Asset-Backed Securities, SEC
Final Rule Issue Effective Date Compliance Date
January 25, 2011 March 28, 2011 December 31, 2011

Issuer Review of Assets in Offerings of Asset-Backed Securities
November 15, 2010

In the comment letter, the Investment Company Institute supports the disclosure of assets underlying an asset-backed security, the use of a third-party reviewer and the monthly disclosure of fulfilled and unfulfilled repurchase requests. The Institute also agrees with the SEC's proposal to require ABS information, contractual or otherwise, to be included in a report produced by nationally recognized statistical rating organization (NRSRO report) as a single source for investors. Questions and concerns regarding the proposed definition of "asset-backed security" are also addressed in the letter.



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