Regulation AB
Item 1111

April 19, 2018

Response of the Office of Structured Finance
Division of Corporation Finance

John Harris
Senior Vice President, Head of Asset Sales & Securitization
Bank of the West
180 Montgomery Street
San Francisco, California 94104

Dear Mr. Harris:

We are responding to your request for interpretation dated April 3, 2018. To avoid having to recite or summarize the facts set forth in your request, we attach the enclosed copy of your letter. Unless otherwise noted, capitalized terms in this response letter have the same meaning as in your request.

Based on the facts and representations in your request, we concur with your interpretation that the asset-level information requirements under Items 1111(h) and 1125 of Regulation AB, in effect as of the date of this letter, do not apply to loans secured by recreational vehicles.

The foregoing interpretation is based solely on the representations and the facts presented in your request. Any different facts, representations or conditions might require the Commission or the Division of Corporation Finance to reach a different conclusion.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2018/bank-of-the-west-041918-1111.htm