SFA Responds to SEC’s Concept Release Pertaining to RMBS and ABS

On November 25, 2025, the Structured Finance Association (SFA) submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) in response to the SEC’s Concept Release regarding rules pertaining to residential mortgage-backed securities (RMBS) and asset-backed securities (ABS). In the letter, SFA offers feedback on how asset-level disclosures and the definition of asset-backed security could be updated to better reflect today’s structured finance market.

Drawing from work conducted within SFA’s RMBS Data Tape Task Force, the letter outlines ways to encourage a registered RMBS market, while maintaining investor protections and borrower privacy.

Key points from SFA’s response:

1. The SEC should modernize Schedule AL to reflect current market practices. SFA highlights that today’s absence of registered RMBS is due largely to cost and complexity of Schedule AL’s 270 data fields, some of which are duplicative and outdated. SFA recommends revising schedule AL to focus on data investors need to make investment decisions, to clarify definitions, and to better align with 144a market practices. The SFA RMBS Data Tape is a helpful starting point to achieve that goal.
2. The SEC should preserve robust data for investors while maintaining borrower privacy. SFA’s letter emphasizes that investors need access to granular loan-level information to perform necessary due diligence. SFA urges the SEC not to require five-digit ZIP codes and other highly sensitive data to be filed on EDGAR. Instead, the SEC should allow these data elements to be provided through other channels – such as third-party data services – and subject to standardized click-through agreements.
3. SFA encourages the SEC to clarify the definition of “asset-backed security”. SFA recommends that the SEC align the Regulation AB definition of “asset-backed security” with the broader Exchange Act ABS definition and formally codify key SEC guidance.