According to a posting on the Equipment Leasing and Finance Association web site, ELFA members met with the Securities & Exchange Commission’s Office of Structured Finance during ELFA’s Capitol Connections conference in May to discuss the association’s submissions on proposed rules on risk retention and equipment ABS.  The meeting was extremely productive and helped to clarify several areas from ELFA’s previous submissions including:

• The treatment of nonscheduled payments
• Principal payments on horizontal securities
• Overcollateralization
• Reserve account permitted investments
• Asset-level disclosure
• Municipal pass-through ABS

In response to an invitation from the SEC, ELFA has prepared and submitted an additional submission to provide further information on each of these areas. The submission specifically notes how Equipment ABS is different than mortgage and credit card ABS and thus affects the way payments are made on the securities and how horizontal risk utilizes overcollateralization. Further, the submission reinforces ELFA’s belief that pool level data disclosure is the best option for the Commission to require and clarifies how we believe municipal pass-through ABS should be treated.

Read the letter to the Securities and Exchange Commission.