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Disclosure Required by Rule 15Ga-1
Form ABS-15G. The SEC adopted a new Form ABS-15G that is to be used to comply with Rule
15Ga-1. The particular disclosure requirements are included in paragraph (a)(1) of Rule 15Ga-1
and are to be provided in a tabular format. Printable versions of both the new Form ABS-15G
and the tabular format are included at the end of this article.
Disclosure Information. A summary of certain of the information to be disclosed includes: (a)
the asset class (such as single family mortgage loans or credit cards), (b) the name of the “issuing
and listed in the order of the date of formation
, (c) whether the transaction was
Rule 15Ga-1 requires disclosure with respect to any asset-backed security for which “the
underlying transaction agreements contain a covenant to repurchase.” An argument could
be made that the “underlying transaction agreements” include only the documents related
directly to the asset securitization itself and do not extend to the mortgage purchase level
documentation. Until further clarification is provided on this point, a more conservative
interpretation would be that underlying transaction agreement included both those
documents directly and indirectly related to the asset securitization.
Defined in Regulation AB as the trust or other entity created at the direction of the
sponsor or depositor that owns or holds the pool assets and in whose name the asset-
backed securities supported or serviced by the pool assets are issued.
Registered with the SEC and disclosure of the CIK number of the issuing entity (as
(d) the name of the originator of the underlying assets and include all originators that
originated assets in the asset pools for each issuing entity, (e) the number, outstanding
principal balance and percentage by principal balance of assets at the time of
securitization, (f) the number, outstanding principal balance and percentage by principal
balance of assets that were subject to a demand to repurchase or replace for breach of
warranties and representations, (g) the number, outstanding principal balance and
percentage by principal balance of assets that were repurchased or replaced for breach of
warranties and representations, and (h) the number, outstanding principal balance and
percentage by principal balance of assets that are (1) pending repurchase or replacement
for breach of warranties and representations dues to the expiration of a cure period, (2)
pending repurchase or replacement because the demand is currently in dispute, and (3)
not repurchased or replaced because the demand was withdrawn or rejected.
If any information required to be disclosed is not known or unavailable to the securitizer
without unreasonable expense or effort, the information may be omitted if the securitizer
provides the information it has or can get without unreasonable expense or effort and
includes a statement showing that unreasonable expense or effort would be involved in
obtaining the omitted information.