Kirkland Alert Kirkland & Ellis LLP

“If You Have Nothing To Say” … It Will Still Be A Lot of Work

Rule 15Ga-1 went into effect on January 1, 2012. It requires the reporting of demands to repurchase assets from securitization trusts due to breaches of representations or warranties. Most securitizers outside of the mortgagebacked securities sectors have had no such demands. One might think that such exemplary corporate citizens would be excused from any reporting. But that’s not the case. In fact, it’s a lot of work to report nothing.