Share on LinkedInShare on LinkedIn

ARTICLE · 06 OCTOBER 2025

SEC Solicits Input On RMBS Disclosure And Registration Requirements

Dechert
Dechert
Contributor
Dechert

Dechert

Dechert helps business leaders lead For more than 150 years, we’ve advised the innovators who move...

View firm profile
Explore more from Dechert

On September 26, 2025, the Securities and Exchange Commission (the "Commission") issued a concept release to gather public comments on potential changes to its rules for asset-backed securities ("ABS").

United StatesFinance and Banking
Linda Ann Bartosch
Linda Ann Bartosch
Ralph Mazzeo
Ralph Mazzeo
Andrew Pontano
Andrew Pontano
William Luciani
William Luciani
Caitlin Q. Kelley
Caitlin Q. Kelley

On September 26, 2025, the Securities and Exchange Commission (the "Commission") issued a concept release to gather public comments on potential changes to its rules for asset-backed securities ("ABS"). The release focuses particularly on residential mortgage-backed securities ("RMBS").

The Commission's action is in response to the fact that there have been no registered RMBS offerings since the adoption of Regulation AB II in 2014, with all activity instead occurring in the registration-exempt private market, largely pursuant to Rule 144A of the Securities Act of 1933 ("Rule 144A").

Across 39 questions covering three primary topics, the concept release examines and requests public comment on whether changes should be made to the current rules in order to "revive the public RMBS market" and "make securitization great again". This sentiment comes on the heels of an estimated $1.6 trillion in mortgage-backed securities issuances last year, according to the

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

New NYSE Delisting Rules: What Microcap Companies Need To Know About The $0.25 Minimum Trading Price

The SEC has approved new NYSE and NYSE American listing rules establishing a $0.25 minimum trading price, effective July 1, 2027. A single closing price below this threshold triggers immediate trading suspension and delisting proceedings with no cure period. Companies trading at low share prices must act now during the transition period to implement reverse stock splits and establish monitoring procedures before this hard floor takes effect.
United StatesFinance and Banking
Bevilacqua
Bevilacqua
Article

SEC And CFTC Open Door To Tokenized Markets After Clarity Fails To Advance

The SEC and CFTC have issued coordinated regulatory relief measures that significantly advance crypto-based trading infrastructure in US markets, bypassing Congressional gridlock on the CLARITY Act. These orders establish new frameworks for tokenized securities venues and passive software providers, potentially reshaping how digital assets are traded and accessed in regulated markets.
United StatesFinance and Banking
K&L Gates
K&L Gates
Article

The SEC’s Proposed “Regulation Crypto Assets” Provides A New Framework For Regulatory Clarity

The U.S. Securities and Exchange Commission has proposed Regulation Crypto Assets, introducing two new exemptions from registration requirements and a safe harbor provision for investment contracts involving crypto assets. How will these tailored frameworks—the Startup Exemption for offerings up to $5M and the Fundraising Exemption for larger capital raises—reshape the regulatory landscape for digital asset issuers while preserving investor protections?
United StatesFinance and Banking
Winston Taylor
Winston Taylor
Article

HRSA Announces Updated 340B Rebate Model Pilot Program, Limited To Drugs Subject To A Maximum Fair Price (MFP) For 2026 And 2027

The Health Resources and Services Administration has announced a revised 340B Rebate Model Pilot Program for drugs subject to Medicare's Maximum Fair Price, expanding eligibility to manufacturers with selected drugs for 2026 and 2027. The program introduces new data requirements, dispute resolution mechanisms, and stricter compliance monitoring while addressing stakeholder concerns about administrative burden and program integrity.
United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

The Financing Problem Behind the AI Infrastructure Boom: What Lenders and Sponsors Need to Watch

As AI infrastructure spending surges toward $697 billion in 2026, hyperscalers and compute providers are increasingly turning to debt, structured financing, and GPU-backed collateral to fund expansion. While demand projections remain bullish, a critical timing gap is emerging between capital deployment and cash flow generation, creating significant risks for lenders, sponsors, and operators across the ecosystem.
United StatesFinance and Banking
Riveron
Riveron
Article

SEC Issues “Innovation Exemption” To Facilitate Trading Of Tokenized NMS Stock

The SEC has issued a groundbreaking Innovation Exemption allowing tokenized securities venues to facilitate trading of tokenized NMS stocks using automated market makers and liquidity pools. This temporary five-year exemption from exchange and dealer registration requirements establishes conditions for permissioned blockchain-based trading while granting public companies a 30-day window to object to third-party tokenization of their securities.
United StatesFinance and Banking
A&O Shearman
A&O Shearman
Article

CLO Equity Fund Market 2026 Update: Clearing Skies

The global CLO equity fund market is experiencing a cautious reopening after a period of tight arbitrage and challenging economics. With U.S. CLO issuance approaching $230 billion in the first half of 2026 and major platforms successfully raising billion-dollar funds, captive and third-party CLO equity fund structures are evolving rapidly as managers deploy sophisticated structuring technologies to provide stable execution capacity and attract institutional capital seeking diversified credit exposure with s
United StatesFinance and Banking
Dechert
Dechert
Article

CFTC Publishes Its 2026 Regulatory Priorities Agenda

The CFTC has released its 2026 regulatory priorities agenda under new Chairman Michael Selig, outlining significant proposed changes to commodity pool operator exemptions, large trader reporting requirements, and foreign exchange product classifications. Asset managers participating in commodities and derivatives markets will need to understand how these regulatory modifications may affect their registration obligations, reporting burdens, and treatment of various financial instruments.
United StatesFinance and Banking
Dechert
Dechert
Article

Preference Given: Preferred Equity's Growing Reach Across Structured Finance

Preferred equity is transforming structured finance by enabling sponsors to attract third-party capital below rated debt without diluting residual positions or triggering additional rating requirements. This analysis examines how CFOs, CLOs, NAV facilities, and other securitization vehicles are deploying bespoke preferred structures to widen investor pools while preserving manager incentives. What contractual mechanics, legal considerations, and market dynamics are driving this shift from niche accommodatio
United StatesFinance and Banking
Dechert
Dechert
Article

Concierge Medicine And Medical Aesthetics: The Private Equity Playbook For A US$590 Billion Opportunity

Private equity investment in concierge medicine, aesthetic dermatology and medispas has surged due to cash-pay economics, recurring revenue models and fragmented markets ripe for consolidation. However, navigating state-by-state corporate practice of medicine prohibitions, licensure requirements and evolving GLP-1 regulations requires sophisticated legal structuring to protect valuations and enable successful exits.
United StatesFood, Drugs, Healthcare, Life Sciences
Dechert
Dechert
Article

Duration Is Not Destiny: The NAIC's Proposal For Multi-Collateral Structured Credit Investments

The NAIC has proposed significant revisions to statutory accounting principles that would restrict bond treatment for multi-collateral structured credit investments deemed to carry "significant embedded asset-liability management risk." This analysis examines the regulatory concerns driving the proposal, evaluates whether the proposed framework appropriately addresses those concerns, and identifies potential unintended consequences for insurance company investors and the broader structured credit markets.
United StatesFinance and Banking
Dechert
Dechert