with which the mortgage lending industry is particularly interested.

Amid the frenzy surrounding implementation of new Loan Officer Compensation rules, on March 29, 2011 the mortgage industry received the first of two major regulatory proposals issued in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The proposed rule is a first look at details of the hotly debated "skin-in-the-game" requirements included in Dodd-Frank. Pursuant to these requirements, "sponsors" of asset-backed securities must retain 5% of the credit risk associated with a security's collateral. In addition, Dodd-Frank exempts certain types of securitization transactions from these risk retention requirements-among them, securities collateralized exclusively by "qualified residential mortgages." The proposal also sets forth definitions for such key terms as "qualified residential mortgage" with which the mortgage lending industry is particularly interested. Importantly, the proposed risk-retention rules permit "securitizers" to allocate a portion of the credit risk which must be retained to the originators of the securitized assets. Because this definition of "originator" refers to the person that creates a loan, only the original creditor of a loan (not a subsequent purchaser) is an originator for the purpose of this rule. As a result of the potential allocation of risk to original creditors, the mortgage lending industry has a vested interest in the final rules governing risk-retention requirements and should take the opportunity to review the proposal in its entirety and submit comments. Below are key points regarding the proposed definition of "Qualified Residential Mortgage" which, since no risk will be allocated to the originator of such assets, is of particular concern to creditors seeking to avoid risk-retention altogether. Qualified Residential Mortgage (QRM) Dodd-Frank requires the definition of QRM to be "no broader than" the definition of "qualified mortgage" set forth, ironically, in the later proposal issued on April 19, 2011. Since sponsors of asset-backed securities collateralized exclusively by QRMs will be exempt from risk-retention requirements entirely, the proposed definition is intended to ensure that such mortgages are of very high credit quality. Whether a residential mortgage is a QRM will be determined at or prior to origination of the mortgage loan. The proposal allows for modification of an individual QRM loan after securitization without jeopardizing the QRM status of the loan in order to promote appropriate loan modification. QRM eligible loans must be a closed-end, first lien mortgage or refinance of a one-to-four family property (at least one unit must be the borrower's principal dwelling). A mortgage loan may qualify as a QRM only if the originator verifies and documents within 90 days prior to closing that the borrower satisfies the following credit history requirements: not currently 30 or more days past due on any debt obligation; not 60 or more days past due on any debt obligation within the preceding 24 months; and, not a debtor in a bankruptcy proceeding, not subjected to property repossession or foreclosure, not engaged in a short sale or deed-in-lieu of foreclosure and not subject to a federal or state judgment for collection of unpaid debts within the preceding 36 months. 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