Adam Altman


Pursuant to Section 941(b) of the Dodd-Frank Act, the federal finance and banking agencies proposed rules requiring securitizers to retain some of the credit risk associated with their securitization transactions. In their proposed rules, the agencies noted that CLO managers fall squarely within their definition of the term "securitizer." Industry participants, however, vehemently contend that CLO man- agers should not be subject to the credit risk retention rules. This note argues that if risk retention is an effective means of promoting responsible securitization activity, regulators should require CLO managers to retain credit risk.