On October 21, 2014, the federal agencies responsible for enforcing the Dodd-Frank Act together issued a statement regarding their joint final rule implementing the law’s credit risk retention requirements. While the final rule provides some clarity as to the scope and nature of the credit risk retention framework generally applicable to all securitization transactions and the risk retention requirements applicable to specific types of securitization transactions, many concerns raised by commenters have not been resolved and are expected to make the consummation of certain types of securitization transactions significantly more challenging.
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