U.S. Securities and Exchange Commission
100 F Street, N.E. Washington, D.C. 20549-1090

Attn: Office of Structured Finance

Re: SEC Chairman’s Statement on Asset-Level Disclosure Requirements for Residential Mortgage-Backed Securities

Dear Chairman Clayton:

On behalf of the American Bankers Association (“ABA”),1 the Housing Policy Council (“HPC”),2 the Mortgage Bankers Association (“MBA”),3 and the Securities Industry and Financial Markets Association (“SIFMA”)4 (collectively the “Associations”), we appreciate your leadership in directing the Securities and Exchange Commission (“SEC” or “Commission”) to review the asset-backed disclosure requirements adopted in the 2014 asset-backed securities (“ABS”) amendments (“Reg AB II”)5 and for providing the public with an opportunity to comment. The Associations’ members represent a large majority of interested parties involved in the residential mortgage-backed securities (“RMBS”) market, including originators, servicers, trust companies, investors, and technology vendors.

1 The American Bankers Association represents banks of all sizes and charters and is the voice for the nation’s $13 trillion banking industry and its 2 million employees. ABA’s extensive resources enhance the success of the nation’s banks and strengthen America’s economy and communities. Learn more at www.aba.com.
2 The Housing Policy Council (HPC) is a trade association whose members are among the nation’s leading mortgage originators, servicers, insurers & data/settlement service providers. Founded in 2003, HPC advocates for a competitive marketplace that embraces accountability, transparency and consistency. Our interest is in the safety and soundness of this system, equitable regulatory treatment of all market participants and the reliance on lending practices that create sustainable home ownership opportunities leading to long-term wealth and community building for families.
3 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, DC, the association works to ensure the continued strength of the nation’s residential and commercial real estate markets, to expand homeownership, and to 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 2,300 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, credit unions, thrifts, REITs, Wall Street conduits, life insurance companies, and others in the mortgage lending field. For additional information, visit MBA’s website: www.mba.org.
4 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate on legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (“GFMA”). For more information, visit http://www.sifma.org. This letter represents the views of issuer and sponsor members of SIFMA.