The SEC is seeking public comment on whether to revise asset-level disclosure (“ALD”) requirements for RMBS and whether to update the definition of “asset-backed security” in Regulation AB (the “Regulation AB ABS Definition”) to conform it to the definition under the Securities Exchange Act of 1934, as amended (the “Exchange Act ABS Definition”). What’s at IssueRMBS Disclosures – Regulation AB II currently requires issuers of registered RMBS to disclose up to 270 data points for each underlying mortgage loan. Definition of ABS – The SEC is reassessing whether the 2004 Regulation AB ABS Definition is too narrow and whether it should be harmonized with the Exchange Act ABS Definition adopted as part of the Dodd-Frank Act. When initially adopted, the Regulation AB ABS Definition was used only for Form S-3 eligibility, and the Commission sought to limit the ABS regime to a definable group of securities. This change would clarify that structures historically outside the Regulation AB ABS Definition—such as —would fall within the registration and reporting framework.