On December 11, 2009, the House of Representatives passed the Wall Street Reform and Consumer Protection Act 0f 2009 (the “Wall Street Reform Bill”).1 The Wall Street Reform Bill consolidates and revises numerous financial reform bills that were introduced in the House of Representatives over the past few months. Title I of the Wall Street Reform Bill contains a revised version of the Financial Stability and Improvement Act of 2009 that was originally released on October 27, 2009.2 Subtitle F of Title I of the Wall Street Reform Bill (also referred to as the Credit Risk Retention Act of 2009) relates specifically to asset-backed securitization reform (the “House ABS Bill”) and was also revised to address issues raised by industry participants after release of the October draft (the “October ABS Proposal”). The differences between the House ABS Bill and the October ABS Proposal are outlined below.
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