Rule 191

Definition of "Issuer" in Section 2(a)(4) of the Act in relation to
Asset-Backed Securities

The following applies with respect to asset-backed securities under the Act. Terms used in this section have the same meaning as in Item 1101 of Regulation AB (§ 229.1101 of this chapter).

a. The depositor for the asset-backed securities acting solely in its capacity as depositor to the issuing entity is the "issuer" for purposes of the asset-backed securities of that issuing entity.

b. The person acting in the capacity as the depositor specified in paragraph (a) of this section is a different "issuer" from that same person acting as a depositor for another issuing entity or for purposes of that persons own securities.