Letters

Disclosure Obligations of Certain Derivatives Counterparties

Summary

The Bond Market Association (TBMA)*, the International Swaps and Derivatives Association, Inc. (ISDA), and American Securitization Forum (ASF) provide comments to the Securities and Exchange Commission (SEC) on disclosure obligations of certain derivatives counterparties under Item 1115 and Item 1114 of Regulation AB.  The Associations briefs the SEC on the duplicity and inefficiency of the proposal.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.

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Date

8

June

2006