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Title: MBA and MISMO® Comment on ASF's Project RESTART RMBS Data Disclosure Package
Source: MBA
Date: 8/25/2008

August 25, 2008


Members of the Media,

The Mortgage Bankers Association (MBA) and MISMO, MBA’s data standards subsidiary, sent the attached letters to the American Securitization Forum (ASF) today in response to ASF’s request for comment pertaining to its Project RESTART RMBS Data Disclosure Package.  MBA shares ASF’s commitment to restoring investor confidence and reinvigorating the flow of liquidity in the housing finance system through trade association coalition and data standards activities.  MBA fully anticipates representing the mortgage banking industry as ASF moves the initiative forward.

The MISMO submittal letter answers specific questions posed in ASF’s request for comment.  It cross references MISMO’s Logical Data Dictionary to the data set that comprises ASF’s RMBS Data Disclosure Package.  It also assesses the areas where the data is aligned while outlining specific gaps that may require additional attention. 

In the MBA submittal letter, John Courson, MBA’s Chief Operating Officer, voiced MBA’s support for incorporation of a unique loan identifier within the ASF framework.  MBA believes that the MERS® MIN is an ideal solution. The inclusion of the MERS® unique loan identifier in the RMBS Data Disclosure Package, as well as other residentially oriented data standard efforts, is consistent with MBA’s view of the benefits derived from standards. MBA believes that such an identifier could play a significant role in helping to re-invigorate the RMBS market.  While MBA supports certain aspects of ASF’s Data Disclosure Package, MBA has requested ASF reevaluate instances where data ambiguity, logistical difficulties and costs might overshadow the utility of the draft plan’s new data elements.

Should you have questions, please feel free to contact:

Aleis Stokes
(202) 557-2741
astokes@mortgagebankers.org




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