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Dodd-Frank Wall Street Reform and Consumer Protection Act
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Re: |
PNC Bank, N.A. |
Capitalized terms used in this response have the same meaning as defined in your letter.
Pursuant to Section 943 of the Dodd-Frank Act, Rule 15Ga-1 requires securitizers of asset-backed securities to disclose fulfilled and unfulfilled repurchase requests.
We understand that issuers of Ginnie Mae MBS provide disclosure related to repurchase activity and information about those repurchases is publicly available on a website maintained by Ginnie Mae, on a monthly basis, that is generally comparable to the disclosure that would be required by Rule 15Ga-1.
Based on the facts presented, the Division's views are as follows.
The Division will not recommend enforcement action to the Commission if an asset-backed securities issuer:
This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. This response expresses the Division's position on enforcement action only, and does not express any legal conclusions on the questions presented.
Sincerely,
Rolaine S. Bancroft
Senior Special Counsel
The Incoming Letter is in Acrobat format.
http://www.sec.gov/divisions/corpfin/cf-noaction/2012/pncbank020112-15ga1.htm
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