Risk Retention Re-Proposed: Game Changers

September 25, 2013

Some Big Questions:

  1. Where does the risk retention re-proposal fall in the overall regulatory landscape?
  2. What is a quality securitization? Have the regulators gone beyond their Dodd-Frank authority/mission into the realm of product paternalism?
  3. Who should hold the risk? Do the regulators have it right?
  4. How do we measure risk? Is it practical to measure fair value for some transactions?
  5. Do we have to change the way we do business? (Will technical issues persist in final rule?)
  6. What do we have to disclose to the market? To Uncle Sam? What problems and issues might result from such additional disclosure?
  7. What is the utility of the safe harbors in the re-proposal?

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