Our Industry Guide initiative seeks to contribute to market openness and transparency via a series of guides that reflect “general consensus” opinions of members interested in those particular regulatory rulemakings.
For more than a year, the SFIG Risk Retention Industry Guide Working Group, including, but not limited to, issuers, investors, lawyers, accountants, trustees, and underwriters, have worked together to define a consistent approach to interpretation and implementation of the Risk Retention rule.
This guide is the third in SFIG’s series of industry guides, following the release of our NRSRO Industry Guide in June of 2015 and our interim Risk Retention Industry Guide in December of 2015, ahead of the RMBS compliance date.
Developed under the leadership of Julie Gillespie of Mayer Brown, the views set forth in the Industry Guide do not constitute legal advice but instead reflect industry views and consensus positions on the questions presented based on various resources and numerous group discussions. All of the views set forth in the Industry Guide are subject to change as market practices develop and/or if additional guidance from the regulatory agencies becomes available. While presented as a consensus, we would highlight that the guide does not purport to represent that all viewpoints have been universally adopted by every SFIG member.