ASF: Dodd-Frank Title VII Proposal Rife With Unintended Consequences for Securitizations
December 14, 2012
Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act will carry two key unintended consequences for the structured finance industry should it be implemented in its current form, a trade group representative warned lawmakers this week. Testifying before the House Financial Services Subcommittee on Capital Markets and Government-Sponsored Enterprises, American Securitization Forum Executive Director Tom Deutsch said that Title VIIs treatment of commodity pools and margin requirements triggers two potential compliance challenges for some parties in securitization transactions that may hurt all of the beneficiaries of the deal. We would not have expected...