Pool Asset Reviews (Section 945)
In January 2011, the SEC adopted final regulations implementing Section 945 of Dodd-Frank. Securities Act Rule 193 requires ABS issuers in SEC-registered transactions to perform a review of the underlying pool assets and amendments to Item 1111 of Regulation AB require these issuers to disclose the nature, findings and conclusions of that review in the prospectus.
The new rules apply to any registered offering of ABS commencing with an initial bona fide offer after December 31, 2011.
- SEC Proposed Rule: Issuer Review of Assets in Offering of Asset-Backed Securities - October 19, 2010