April 2, 2012
On March 26, 2012, Reps. Bachus (R-AL) and Garrett (R-NJ) issued a letter expressing concern to six banking agencies regarding their risk retention proposal, which contained a requirement that securitizers set aside the profits from sales of securities in a “premium capture cash reserve accounts” (PCCRAs). Specifically, the two lawmakers raised concerns that this provision would greatly reduce the securitization market for many asset classes, thereby reducing a vital source of capital for the commercial real estate industry. Given this potential negative economic consequence, the letter asked the banking agencies to provide Congress with a cost-benefit analysis of their PCCRA proposed rule.