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Legal Update

FINRA Amends Proposal for TRACE Reporting for Most Asset-Backed Securities and Excludes CDOs (including CLOs) and Non-Agency-Backed CMBS

24 February 2014
Mayer Brown Legal Update

On February 14, 2014, the Financial Industry Regulatory Authority (FINRA) filed a response to comments submitted by the Securities Industry and Financial Markets Association (SIFMA) to the Securities and Exchange Commission (SEC) regarding FINRA’s Proposed Rule Change Relating to TRACE Reporting and Dissemination of Transactions in Additional Asset-Backed Securities (the Proposal).1

SIFMA argued that the credit analysis for collateralized debt obligations (CDOs), including collateralized bond obligations (CBOs) and collateralized loan obligations (CLOs), and non-agency-backed commercial mortgage-backed securities (Non-Agency-Backed CMBS) differs from that for other securitized products. In response to SIFMA’s comments, FINRA proposes to exclude CDOs, CBOs, CLOs and Non-Agency-Backed CMBS from the Proposal.

For more information about the topics addressed in this Legal Update, please contact J. Paul Forrester or your regular Mayer Brown lawyer.


1 The earlier proposed rule change is described in our related Legal Update available at:


  • J. Paul Forrester
    T +1 312 701 7366
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