It would be more beneficial to the pool assemblers if either more than 1 increment of $500,000 per loan could be included in a pool or allowing larger increments from a large loan, i.e. $1.5mm maximum per loan.
For the current maximum loan size, $5mm with $3.75mm gtd, using $500,000 increments limited to 1 per pool would require issuance of 8 pools resulting in a much longer holding period for the pool assemblers.
The risk to the pool assemblers has not been mitigated under this proposed program change due to a further extended holding period.
Comment on FR Doc # 2011-26236
This is comment on Rule
Small Business Jobs Act: Implementation of Conforming and Technical Amendments
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