IACPM Submits Follow-Up Letter and Research Results to SEC on Proposed Rule 127B

The IACPM sent a follow-up to the Comment Letter to the SEC in response to SEC’s proposed rule 127B, dated February 6, 2012.  This second letter is a reply to observations made and questions posed during a meeting of SEC staff with members of the International Association of Credit Portfolio Managers (IACPM), Citigroup, Deutsche Bank and Sullivan & Cromwell on April 25, 2012 (memorandum).  The letter includes the aggregate results of an IACPM member survey on synthetic securitizations which had been conducted among IACPM member firms to help the SEC staff gauge the size of the market.

Supplement to the February 6 Comment Letter.

All comments to the SEC are publicly available on the SEC website.