SFA Responds to the OMB’s RFI: Deregulation

The Structured Finance Association (SFA) worked with relevant Committees and Task Forces to submit a response to the Office of Management and Budget’s (OMB) Request for Information (RFI): Deregulation.

SFA’s request makes recommendations for the following items

• FinCEN’s Corporate Transparency Act – the SFA and its members ask that securitization issuing entities be categorically exempt from the requirement to report BOI to FinCEN,
• SEC’s Rule 15c2-11 under the Securities Exchange Act of 1934 – the SFA recommends the SEC to clarify that 15c2-11 does not apply to debt securities,
• FDIC’s Proposed Rule: Recordkeeping for Custodial Accounts – the SFA recommends that the proposal be rescinded.
• The joint banking regulators’ Proposed Basel III Regulatory Capital Rule – the SFA reiterates the points made in its previously submitted response.

To see the SFA’s response, submitted separately, to the OMB RFI: Deregulation requesting that securitization vehicles be excluded from the definition of ‘commodity pool operators’, please see here.