On October 21 and 22, 2014, pursuant to the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), the Securities and Exchange Commission (the “SEC”) and various federal banking and housing agencies adopted credit risk retention rules for securitizations. These rules, which were first proposed on March 29, 2011, and re-proposed on August 28, 2013, provide several methods of retaining the required 5 percent risk exposure, as well as limited exceptions for pools of assets that satisfy specified credit criteria.
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