September 24, 2013
Required Information provided in RED below for this Comment on "Credit Risk Retention" solicited from the General Public by the combined:
1. “OCC” is the agency name
2. “Docket Number OCC-2013-0010
In this U.S. Treasury web site:
My Comments below:
The proposal indicates a minimum of 5% Credit Risk Retention for "Assets Collateralized by Asset Backed Securities"
and exempts certain residential mortgages classified as “qualified residential mortgages” backed securities:
A. I would strongly recommend the minimum 5% Credit Risk Retention be higher as 20% despite some of the
known liquidity disadvantages to this higher value.
B. I would strongly recommend the proposed NO EXEMPTION for “qualified residential mortgages” be removed as
an exemption so those securities also be included similar to other ABSs, again despite known disadvantages to
this exclusion omission.
The rationale for both these comments and recommendations are rooted in the recent past financial problems and that
a "mere" 5% will hardly alter behavior and thereby NOT cause any significant change in behavior which is supposedly
the intent of this Proposed Rule. Simply stated, 5% will NOT accomplish the intended purpose.
I may be reached at this e-mail address if desired or necessary, but my e-mail address is not noted here so it will not
be disclosed with my comments.