From: Emile Van den Bol
Sent: February 16, 2007
Subject: File No. S7-07-07

To whom it may concern:

My name is Emile Van den Bol and I work for Deutsche Bank. My employer is a significant participant in the structured finance and securitization industry. My title is Global Head CRE CDOs and Global Co-Head Specialty Finance Group of the Commercial Real Estate Business.

We find that the ratings among agencies are very comparable, and the new proposed rule is addressing the issue to some extend, but we do not see a good reason to limit the bucket of assets not rated by the specific rating agency to 15%. We feel that the limited size of this bucket still creates leverage for agencies they should not have. The 15% is somewhat arbitrary and in our view to restrictive. We would propose to increase the bucket to 50%.
If you would like to get more background on our position please don't hesitate to contact me.

Kind Regards,

Emile Van den Bol

Managing Director
Deutsche Bank
60 Wall Street
New York, NY 10005