The Dodd- Frank Bill has laid out a pathway for future operations in the financial services arena. However, the road has not yet been paved. The job of laying the pavement has been left to individual industry regulators who have 270 days from the date of passage to develop, write, publish, submit for comment and issue as final the regulation which will govern our business for the foreseeable future. This guidance giving, as opposed to concrete rulemaking, has created confusion in interpreting new risk retention rules.
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