SEC Sets Compliance Date for Asset-Level Disclosure

The SEC set the compliance date for amendments to Regulation AB. Regulation AB consolidates and codifies existing interpretative positions that clarify Securities Act of 1933 registration requirements for asset backed securities offerings. The relevant amendments require asset-level disclosure for offerings of asset-backed securities backed by residential mortgages, commercial mortgages, auto loans, auto leases and debt securitizations (including resecuritizations).

The asset-level data requirements are applicable only to securitizations in which the initial bona fide offer occurs on or after November 23, 2016. A registrant who makes an initial bona fide offer on or after that date must provide asset-level disclosure in accordance with the requirements of Regulation AB in the prospectus at the time of the offering and then on an ongoing basis with each Form 10-D filing. Securitizations for which offers are made prior to November 23, 2016 are not required to provide asset-level disclosures in their prospectuses or on an ongoing basis with each Form 10-D.