New Rules For Third-Party Due Diligence Reports For Asset-Backed Securities

On August 27, 2014, the Securities and Exchange Commission (the "SEC") adopted final rules¹ (the "Final Rules") implementing, among other things, provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act") relating to third-party due diligence reports for asset-backed securities²("ABS").  As adopted, the Final Rules will require:

       (i)            issuers and underwriters of rated ABS, whether or not registered with the SEC, to file with the SEC, at least five business days before the first sale in the ABS offering, a Form ABS-15G containing the findings and conclusions of reports of third-parties who have been employed to provide due diligence services,