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Yesterday, Corp Fin issued a couple of new and revised CDIs relating to asset backed securities.  Revised CDI 112.01 addresses the forms to be used for registration statements and periodic reports for issuers engaging in public utility securitizations. Here’s a marked copy of the changes. New CDI 112.02 updates guidance for public utility securitizations contained in a 2007 no-action letter and clarifies that the guidance in CDI 112.01 supersedes the guidance contained in that letter.

The new CDIs follow on the heels of a no-action letter issued to SIFMA last Friday which provides guidance to asset backed securitization participants on how to avoid running afoul of the prohibition on certain conflicted transactions set forth in Rule 192(a)(3)(iii) under the Securities Act.

Those of you who aren’t involved in securitizations are probably saying “so what?” at this point in the blog. However, Staff participants in yesterday’s “SEC Speaks” conference noted that this no-action letter illustrates a broader point about the Staff’s willingness to work with market participants after rulemaking. Apparently, the Office of Structured Finance engaged with SIFMA and discovered that market participants were working to comply with the relevant section of Rule 192, but there were ambiguities that needed to be addressed – and that’s what the no-action letter is intended to accomplish.