Subject: File No. S7-21-04
From: James E Myers

July 12, 2004

Lewtan Technologies wants the SEC to be aware of the existence of vendors like Lewtan that provide productized solutions for addressing Static Pool Analysis as proposed by the SEC. Lewtans solution, for example, has already been adopted and recognized as best practice by many major issuers in the ABS market for both initial disclosure and ongoing reporting.

The statistics that should be provided on a static pool basis are those variables predictive of the credit performance and payment speeds of the assets underlying a securitization. These statistics would certainly vary by asset type and could conceivably vary from sponsor to sponsor.

Providing updated statistics along the dimensions quantified in an initial static pool disclosure facilitates transparency and liquidity in the secondary market by creating a new snapshot of more detailed collateral information than that which is currently standard market practice.