Opportunity for Issuers to Receive Feedback on Test Filings in Preparation for Asset-Backed Securities Offerings That Require Asset-Level Data
April 29, 2016
Filers may submit test filings of Form ABS-EE, the form used to disclose asset-level data for offerings of asset-backed securities (ABS).
Under SEC rules, registered ABS offerings backed by residential mortgages, commercial mortgages, auto loans, auto leases, and debt securities (including resecuritizations) must comply with asset-level disclosure requirements. An ABS issuer that makes an initial bona fide offer on or after November 23, 2016 must provide asset-level disclosures that are specified in Schedule AL (Item 1125 of Regulation AB) and filed on new Form ABS-EE in a standardized tagged format using eXtensible Markup Language (XML).
Beginning on May 1, issuers may request that SEC staff provide feedback on a test filing for compliance with the new rules, prior to the compliance date. Test filings received by July 15, 2016 will be eligible for staff feedback. Filers wishing to receive such feedback should send an email to ABSEEtestfiling@sec.gov on the same date as the test filing. In the body of the email, please indicate:
- the CIK number and name of the filer;
- the date of filing;
- a statement of your request that the staff provide feedback about the test filing’s compliance with the new rules; and
- the name, telephone number and email address of the person to contact to discuss any compliance feedback.
A test filing submitted for staff feedback should include the XML tags and sample data that are representative of what issuers intend to include in a “live filing.” Staff feedback generally will be provided within two weeks of receipt of a request to review a test filing.
This program is intended to facilitate compliance with the asset-level rules in advance of the compliance date. Compliance with the rules is the responsibility of each issuer. Following the completion of this test filing period, the staff will continue to monitor Form ABS-EE filings for compliance with the new rules.
Test filings, including those submitted for staff feedback, are not and will not be made available for public viewing. As is the case with any document submitted on EDGAR, testers should not submit confidential or personally identifiable information in the test filings.
To make a test filing, issuers must have a Central Index Key (CIK) and a CIK Confirmation Code (CCC). These codes are necessary for filing on EDGAR, and information about how to obtain CIKs is available on the EDGAR Filer Management page. The technical specifications for new Form ABS-EE are located on the SEC’s website. Additional information is available on the Information for EDGAR Filers page. Filers should use normal test filing procedures when submitting a test Form ABS-EE on EDGAR.
The SEC welcomes feedback from testers on the Form ABS-EE filing process. Those who have questions or encounter problems during the testing of Form ABS-EE may email ABSEEtestfiling@sec.gov or call Filer Tech Support at 202-551-8900 (Option #3).
April 29, 2016