Re-REMICS Revisited . . . One of the seminal "technical" articles on the subject (attached) and past official actions(linked)


Re-REMICS Revisited . . . One of the seminal “technical” articles on the subject (attached) and past official actions (linked)

Re-REMICS Revisited . . . One of the seminal “technical” articles on the subject (attached) and past official actions (linked)

Speaking of Securitization

Accounting, tax, regulatory, and other developments affecting transfers and servicing of financial assets

The RE-REMIC phenomenon:

  • Is it a regulatory capital play?
  • Is it a defensive play against further ratings downgrades?
  • Is it a tax-advantaged transaction?
  • Is it a cost-efficient funding strategy for the new AAA securities?
  • Is there an economic trading arbitrage?
  • Does it make AAA bonds more saleable?

Sometimes the impetus for a RE-REMIC1 is one or more of the factors listed above, and in rare circumstances, all of the above. Given the paucity of any new primary issuances in the mortgage securitization market and the yet-to-develop traction in government strategies to revive mortgage securitization, just about the only non-agency game in town are RE-REMIC transactions, and there is no shortage of supply.

This paper will summarize technical accounting, regulatory, and tax issues that apply to these transactions. The paper does not address the credit re-rating analysis or any economic valuation of the sum of the parts in relation to the whole. Because the technical accounting and regulatory developments outlined herein are very fast-moving, readers should be aware that this paper might not represent the up-to-date status of these matters as of the date of their reading.


Down Load PDF of This Case


September 2011
12 USC 24(7)
Resecuritization of Certain Residential Mortgage-Backed Securities


[Federal Register Volume 75, Number 84 (Monday, May 3, 2010)]
[Proposed Rules]
[Pages 23327-23514]
From the Federal Register Online via the Government Printing Office []
[FR Doc No: 2010-8282]
 \456\ 17 CFR 230.144A.
    \457\ See the Rule 144A Adopting Release.
    \458\ For example, a vast majority of resecuritizations of real 
estate mortgage conduits, known as ``Re-Remics,'' are offered 
through resales made in reliance on Rule 144A safe harbor. See 
Deloitte's Speaking of Securitization, ``The Re-Remic Phenomenon'' 
(June 2009), at 2.
    \459\ Many CDOs do not meet the ``discrete pool of assets'' 
component of the Regulation AB definition of an asset-backed 
security because CDOs permit the active management of the assets for 
a period of time (e.g., five years), a component which is 
inconsistent with the principle set forth in Item 1101(c). Also, 
other structured products like synthetic securities do not meet the 
definition of an asset-backed security under Regulation AB. See 
Section III.A.2.a. of the 2004 ABS Adopting Release. In addition, 
actively-managed CDOs and issuers that offer synthetic securities 
generally do not meet the requirements of Rule 3a-7 under the 
Investment Company Act and typically rely on one of the private 
investment company exclusions under that Act. See fn. 39 above.
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One Response to “Re-REMICS Revisited . . . One of the seminal “technical” articles on the subject (attached) and past official actions (linked)”


    MBS, RMBS, REMICS, RE-REMICS, and their ratings, and their raters, are all frauds, and their “bonds” are nothing but worthless junk-bonds backed with nothing at all.

    S&P recently stipulated to pay $1.5 billion fine to USA for fraudulent ratings of MBS, in the court of Hon. Judge David O. Carter, here in Orange County, California, where I believe that Judge Carter had at least two conflicts of interest in that case.
    At first instance I had learned that Judge Carter also works for the U.S. Department of State (Article 2), and thus would have a conflict hearing cases with USA as a party, not to mention the fact of conflict with his appointment as an Article 3 federal judge. Secondly, “Kay Rackauckas”, one of the lawyers representing S&P was a former Deputy District Attorney in Orange County, evidently at the same time Judge Carter was a chief prosecutor in that same office, thus being former co-workers.
    I don’t believe that Judge Carter filed any declarations of these potential conflicts of interest in that case, just as he did not disclose his apparent conflicts of interest in my cases in his court, where his former employer (the County of Orange) is a defendant, in addition to his former state associate Judge William Monroe, also as a defendant.

    Judge Monroe, and hundreds of other courts nationwide, have conspired with “Wells Fargo Drug Cartel” lawyers in the theft and laundering probably several million houses, in furtherance of the Cartels $1/2 trillion drug money laundering operations (see Wachovia-Wells Fargo confession of judgment at top link of above webpage).

    In my personal case, multiple defendants including “Cameron Merage” in his forgery operations, also known as: “First Team real Estate” and “Coast Cities Escrow”, had forged my loan and grant deed documents for theft and laundering of money and real estate, in close conspiracy with title companies like “Fidelity’s Commonwealth Title”. I believe that the “Cameron Merage forgery network” has been doing this counterfeiting operation for at least 20 years, and against thousands of victims. Their lawyers are similarly fraudsters, and forgers, as they have even forged court papers, such as deposition transcripts in my cases.

    I believe that reports like this “expert accounting report” are also frauds, in and of themselves, and in furtherance of the continuing U.S. criminal counterfeit industry (a/k/a: U.S. Financial Industry), which includes U.S. “rating” and “accounting” firms.

    In the above-mentioned S&P case, S&P confessed that its ratings amounted to only “puffery”, and marketing hype, and that its ratings are devoid of any relations to the quality of any bonds, yet they have been allowed to continue their AAA rating-fakeries, just as the MBS junk bond counterfeits have also continued relentlessly ever since, and one of those continuing criminal counterfeit operations is what this report calls RE-REMICS, which amounts to re-counterfeiting of already counterfeited junk bonds!

    I have documented these in court papers all the way up to the U.S. Supreme Court case 11-1013.

    GOOGLE: “Kay Rackauckas evading grand jury” for some details on the Deputy DA who was at that time the wife of the current OCDA Tony Rackauckas. Here’s one still available article:

    If you want my “Witness Testimony”, with my proofs of facts, against any one of the above named entities, or individuals, please contact me at:

    Refunds paid, if my proofs-of-facts can be disproved by anyone.

    “Kareem Salessi 11/3/15”


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