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On July 26, 2011 the Securities and Exchange Commission (the 'SEC') issued a release (the 'Proposing Release') revising and re-proposing certain rules (the 'Proposed Rules') initially proposed in April 2010 related to asset-backed securities in light of the provisions added by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the 'Dodd-Frank Act') and comments received on the 2010 ABS Proposals. Among other things, the 2010 ABS Proposals propose amendments to the safe harbor for exempt offerings and resales for 'structured finance products' in reliance on Securities Act Rule 144A, which would include many Insurance-Linked Securities ('ILS') such as CAT bonds. Under the Proposing Release, the SEC has requested additional comment on these proposals relating to exempt offerings