February 27, 2014


Structured Finance

SEC Seeks Comment on Proposed Approach Under Regulation AB II for the Dissemination of Potentially Sensitive Asset-Level Data

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Katharine Crost
Alan Knoll
Al Sawyers
Robert Moyle
David Ridenour

On February 25, 2014, the Securities and Exchange Commission (the "SEC") re-opened the comment period on the series of proposed rules commonly referred to as "Regulation AB II."  Specifically, the SEC is seeking comment on a proposed approach for the dissemination of potentially sensitive asset-level data to investors whereby an issuer would post such information on an issuer-sponsored website, which could be access-restricted, rather than file such information publicly with the SEC.  This proposed approach is outlined in an SEC staff memorandum included in the public comment file for Regulation AB II. The deadline for comments on the proposed approach is March 28, 2014.

Please click here for our summary.