Sears Roebuck Acceptance Corp

This question is related to, and forms part of, issue #2018101502. Pursuant to the CDS definitions (2014 and amended 2003) and the DC rules, any obligation of a reference entity that is determined to be a “Deliverable Obligation” of such reference entity should be included in the final list of deliverable obligations that will be used in the CDS auction related to the settlement of the CDS referencing such entity. With respect to SRAC, we note that neither the initial list published nor any of the meeting statements made a determination on, or definitively addressed the issue of, whether any of the “Eligible Assignee Loans” referenced in the November 5 statement is a Deliverable Obligation of SRAC. We request that the DC either (a) make a determination on whether any of the “Eligible Assignee Loans” is a Deliverable Obligation of SRAC or (b) based on the divided nature of the voting on the initial list, and the lack of a supermajority, refer the question to an external review panel as allowed for under the DC rules. Furthermore, if any of the “Eligible Assignee Loans” is determined to be a Deliverable Obligation of SRAC, we request that such loan be added to the final list of deliverable obligations for SRAC auction. We believe this issue has a significant impact on the upcoming SRAC auction and the question needs to be definitively answered/resolved before any SRAC auction is held (so we would also request that the auction date be pushed back if the DC or the external review panel needs more time to provide a definitive resolution).