The following Letter Type A, or variations thereof, was submitted by individuals or entities.Letter Type A:We appreciate the SEC’s initiative to review and modernize RMBS disclosure requirements. As a group of business students studying accounting and finance, we believe this rule could make a meaningful difference in improving investor understanding of mortgage-backed securities. Based on the information in the proposal, we support standardized asset-level disclosures because they will help investors make better, data-driven decisions. In our view, a clearer set of reporting fields—especially regarding loan-to-value ratios, borrower credit ranges, and delinquency history—would increase confidence in the secondary mortgage market. However, to make the rule more practical, we recommend a two-year phase-in period for smaller or first-time RMBS issuers. This would give firms time to update internal systems, train staff, and test data collection processes before full compliance. In addition, the SEC could help by publishing sample templates or examples of the required disclosure formats. These steps would make implementation smoother while still meeting the rule’s transparency goals. Overall, we strongly support the effort to improve the clarity and consistency of RMBS reporting because it will help both investors and issuers operate with greater trust and understanding.
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