Abstract
The first year for which most ABS issuers were required to comply with the new servicer attestation requirements of Item 1122 of Regulation AB has just come to a close. Although the period over which management assessed compliance with the servicing criteria detailed in Item 1122(d) (“1122 Criteria”) is recent history, certain aspects of the accountant9s attestation process continue to present current challenges for all of us. Two areas demanding attention subsequent to the end of the attestation period are 1) considerations on reporting and 2) considerations on completing the attestation on third parties classified as vendors.
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