Mr Cooper Group Inc (COOP)

[Johnnyiwantsome]

Rule 360 Safe Harbor Post WAMU
FDIC Securitization Rule FDIC POST WAMU
The way I see it is there is a AWHOLELOTAA Assets that got protected and under even the new law some very big ones still would be untouchable. REMEMBER KILLINGER&FISHMAN/ MANAGEMENT KNEW THEY WERE GOING TO GET ROLLED! The truth is most of the assets were all safe harbored or off Books long before.


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www.sullcrom.com
May 21, 2010
FDIC Securitization Rule
FDIC Proposes Revised Securitization Rule Including Safe Harbors for
Securitization Transactions Not Entitled to Off Balance Sheet
Treatment under New Accounting Standards
SUMMARY
On May 11, 2010, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking to
address the safe harbor protection in a receivership or conservatorship for financial assets transferred by
an insured depository institution in connection with a securitization or participation after September 30,
2010. This action was prompted by the changes adopted by the Financial Accounting Standards Board in
June 2009 to the accounting standards on which the FDIC’s existing Rule 360.6 is based and builds on a
draft rule presented by the FDIC in an Advance Notice of Proposed Rulemaking issued for public
comment in December 2009. The FDIC is seeking comment on the proposals on or before July 1, 2010.
Similar to existing FDIC Rule 360.6, the proposed rule would protect securitizations made after
September 30, 2010 from repudiation by the FDIC as receiver or conservator if the transfer of financial
assets under the securitization qualifies for sale accounting treatment under generally accepted
accounting principles as in effect for reporting periods beginning after November 15, 2009, except for the
“legal isolation” condition that is addressed by the rule, but the proposed rule would impose substantial
additional conditions that all securitizations must meet to benefit from safe harbor protections after a
grandfathering period ending on September 30, 2010.