17 C.F.R. Part 246, adopted jointly by the Securities and Exchange Commission (“SEC”) and five other federal agencies in October of 2014 (the “U.S. Risk Retention Rules”), requires a sponsor of asset- backed securities (“ABS”) or a majority-owned affiliate of the sponsor to retain an economic interest in the credit risk of securitized assets in accordance with the requirements of the U.S. Risk Retention Rules for a specified period of time. Compliance with the U.S. Risk Retention Rules was required with respect to ABS collateralized by residential mortgages by December 24, 2015 and with respect to all other classes of ABS by December 24, 2016. Considerable uncertainty exists as to whether certain securities constitute ABS for purposes of the application of the U.S. Risk Retention Rules, in particular with respect to more esoteric asset classes.