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On January 25, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) issued a release (the “Re-Proposal”) proposing Rule 192 under the Securities Act of 1933, as amended (the “Securities Act”), a rule that is designed to prohibit “material conflicts of interest” in certain securitizations.  Proposed Rule 192 is intended to implement Section 621 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), which was codified as Section 27B (“Section 27B”) of the Securities Act. https://www.cadwalader.com/resources/clients-friends-memos/sec-re-proposes-a-rule-prohibiting-conflicts-of-interest-in-certain-securitizations