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MBA and 16 Other Groups File Joint Comment Letter on Commercial/Multifamily Risk Retention Proposed Rule

MBA and 16 Other Groups File Joint Comment Letter on Commercial/Multifamily Risk Retention Proposed Rule

Members of Media:

WASHINGTON, D.C. – August 3, 2011 – (RealEstateRama) — The Mortgage Bankers Association (MBA), along with 16 other national real estate and financial services organizations, submitted to federal regulators a joint comment letter in response to the commercial and multifamily real estate elements of the proposed rule on credit risk retention (Proposed Rule).

The Proposed Rule seeks to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934, as added by section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

The joint letter underscores the industry’s common interest in advancing public policy objectives that ensure a liquid, credible, safe and sound securitization market, while supporting the efficient flow of capital for commercial and multifamily real estate. The joint letter also provides recommendations on topics important to the industry, including risk retention structures that consider market dynamism and concerns raised by the proposed premium capture cash reserve account.

To view the comment letter, please click here.

If you have any questions, please contact Matt Robinson at (202) 557-2727, or ">.


The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 280,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nation’s residential and commercial real estate markets; to expand homeownership and extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of over 2,400 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, Wall Street conduits, life insurance companies and others in the mortgage lending field.


Mortgage Bankers Association
1331 L Street, NW
Washington, DC 20005

Phone: (202) 557-2700