March 21, 2014
There is a need for certificateholders and the Commission to have loan level data provided for all loan repurchases as a fwp filing to supplement the ABS 15G filing. Without this information filing entities have no accountability to certificateholders needing to validate repurchase for breaching loans at the loan level against the ABS 15G reporting. Most PSA required the reporting of repurchased loans as part of Section 4, however reporting of repurchased loans in most trusts were discontinued either intentionally or unintentionally at the loan level in the first quarter of 2008, which corresponded with the collapse of many financial institutions. Our initial review of loan repurchases reported under ABS 15G showed for a particular quarter where only one loan was repurchased the principal balance could not be traced back to repurchase activity in the monthly loan level data for that particular period.
To address concerns regarding consumer privacy, the loan level data should include the loan number utilized within the loan level remittance reporting, principal balance repurchased, original loan balance at origination and the note date. This information should be sufficient to trace the loan stated as repurchased back to a loan within the trust so that certificateholders can validate the cash flows from "stated repurchases" and monitor the ABS 15G reporting. Our original review of the ABS 15G reporting leads us to believe filings are either intentionally or unintentionally not being completed accurately.