MBA Response to SEC Conflicts of Interest Proposal

2023 Bank Regulatory Policy Comment Letters Commercial Commercial / Multifamily FHA Multifamily Government Lending Government Servicing Policy Issue
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The Mortgage Bankers Association (MBA)1 appreciates the opportunity to comment on proposed Rule 192 (the “Proposed Rule”)2 under the Securities Act of 1933 (the “Securities Act”). When adopted in its final form by the Securities and Exchange Commission (the “Commission”), Rule 192 will implement Section 27B of the Securities Act (“Section 27B”)3, which prohibits certain material conflicts of interest in securitizations, subject to the exceptions set forth therein.

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