Asset-Backed Securities Regulation - Comment Letter - Loan Syndications and Trading Association - 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, LSTA provides the following opinions:

  • The SEC should exclude CLO closing date letters and internal materials prepared by asset managers from the proposed rule;
  • A CLO manager does not fit the definition of "third party" as set by the proposal; and
  • Specific internal credit materials prepared by the CLO manager should also be excluded from the proposed rule.


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