On February 1, 2012, the SEC's Division of Corporation Finance (DCF) issued a no-action letter indicating that it will not recommend enforcement action under Rule 15Ga-1 of the Exchange Act against issuers of Ginnie Mae mortgage-backed securities (MBS) under certain conditions. As required under the Dodd-Frank Act, Rule 15Ga-1 requires securitizers of asset-backed securities (ABS), including MBS, to disclose fulfilled and unfulfilled loan repurchase requests to the SEC.

Because disclosure on repurchase activity by issuers of these securities is publicly available on Ginnie Mae's website, the DCF will not recommend enforcement for non-compliance with Rule 15Ga-1 disclosures if a Ginnie Mae MBS issuer continues to report Ginnie Mae MBS repurchase activity to Ginnie Mae and the information continues to be made publicly available on a monthly basis on Ginnie Mae's website.

Issuers of Ginnie Mae MBS are also:

In cases where the issuer of Ginnie Mae MBS is otherwise obligated to file a Form ABS-15G, it may exclude from listing in the table on the form any Ginnie Mae MBS that would otherwise be required to be listed. However, these issuers must include a statement that they are issuers of Ginnie Mae MBS and provide the "tabular" disclosures required by Rule 15Ga-1(a)(1) for any specific Ginnie Mae MBS issuance for which there was repurchase activity during the period. Where no repurchase activity occurred during the period, these issuers may simply report that there has been no activity for that period.

Ginnie Mae is a Government Sponsored Enterprise or GSE, like Fannie Mae and Freddie Mac. MBS in which the underlying loan pool is composed entirely of mortgage loans originated by GSEs are generally referred to as "agency" MBS. "Private label" MBS are MBS in which the underlying pool of mortgages were privately originated. The no-action letter mentions nothing regarding disclosure of other types of agency MBS, such as those originated by Fannie Mae and Freddie Mac.