Securitization Reform (as of January 1, 2010)

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Securitization of sub-prime mortgages was identified as contributing to the financial crisis. The shift of credit risk to off-balance sheet vehicles was a major focal point for regulators. As a result, earlier this year, the FASB revised accounting rules and provided guidance relating to sales of financial assets and consolidation of certain off-balance sheet entities. In December 2009, the FDIC announced proposed rulemaking amending its securitization safe harbor rules to require financial institutions to retain more of the credit risk from securitizations and to reflect the recent accounting changes. Below are the key securitization reform measures we expect Congress to address in 2010.

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