John Dugan, Former Bank Lobbyist and Comptroller of the Currency: Apologist for Debt Securitization, and the Resulting Moral Hazard?
"To the extent that true sale and off-balance sheet treatment really are important factors for
re-starting a vibrant securitization market - and I suspect they are - an on-balance sheet result
caused by a mandatory "skin-in-the-game" requirement would certainly be perverse. That is, a
requirement intended to improve the securitization market by improving the quality and
trustworthiness of underwriting could significantly curtail the number of securitizations that are
actually done. And that, of course, could materially reduce the amount of credit available for
housing or any of the other sectors that have traditionally benefited from securitization. "
- John C. Dugan - Comptroller of the Currency
Remarks
by
John C. Dugan
Comptroller of the Currency
before the
American Securitization Forum
February 2, 2010
"Securitization, 'Skin-in-the-Game' Proposals,
and Minimum Mortgage Underwriting Standards"



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