Subject: File No. S7-08-10
From: Colm O hAonghusa, BE,MBA,ACA

April 8, 2010

A key piece of information that needs to be readily available is the the risk transfer profile (aka risk cascade) in the event that the securities perform less than 'swimmingly'.

While much of the underlying ABS documentation is 'boiler plate' and accepted as standard, there are cases where the risk transfer profile has been surreptitiously altered with devastating consequences.