SIFMA and ASF provides comments to the Board of Governors of the Federal Reserve System on the home equity lending market and a proposal to amend rules provided in the Home Ownership Equity Protection Act, Docket No. OP-128.  Due to the importance of mortgage-backed investment vehicles in the securitization markets, SIFMA and ASF have been studying and discussing with their members initiatives of federal and state policymakers to address the challenges in the subprime mortgage industry. While many of the groups’ members do not directly act as mortgage creditors or interact directly with consumers, the members recognize that the nation’s well-functioning and efficient mortgage securities markets, which ensure American homeowners (and future homeowners) have access to affordable mortgage loans, will depend upon and be deeply affected by the government’s response to subprime challenges.