Subject: File No. S7-08-10
From: Donald E Kelly
Affiliation: Real Estate Valuation Advocacy Association

August 3, 2010

In regard to: Asset-Backed Securities file No. S7-08-10

The Real Estate Valuation Advocacy Association (REVAA) is an alliance of real estate related companies that develop and deliver valuation products to lenders, investors, agencies and others. These products include Broker Price Opinions, Automated Valuation Models, appraisals, and other collateral valuation products demanded in the marketplace.

Broker Price Opinions are particularly helpful to the lending community as mortgage loans are being examined and are subject to modification under HAMP or other programs and by servicers attempting loan workouts or foreclosures. More than 10 million BPOs were performed last year for these purposes.
There is a continuing need for these effective and efficient products in today's mortgage loan environment.

As a technical matter, we believe your draft should be consistent with the industry definition of BPO as a "Broker Price Opinion" when referenced in the regulation.

Thank you for your consideration.

Don Kelly, EVP
734 15th St NW Ste 900
Washington, DC 20005