MBA, CREFC Letter to SEC on CMBS Compliance Documentation
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The signed organizations appreciate the time spent on January 25, 2024 clarifying questions with respect to the letter of October 12, 2023 (the “October Letter”) regarding Compliance & Disclosure Interpretation 111.01, Form SF-3 Eligibility Requirements, Timely Transaction Documents (the “C&DI”) published on August 30, 2023 by the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC” or the “Commission”). Responses have been set forth to the Division’s questions below, commencing with Section II, by first restating the understanding as to the Division’s questions and following with responses.
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