Seems like this covers it: https://www.trepp.com/TreppTalk/bid/333936/What-Qualifies-Risk-Retention-in-CMBS https://www.trepp.com/TreppTalk/bid/333936/What-Qual

Seems like this covers it: https://www.trepp.com/TreppTalk/bid/333936/What-Qualifies-Risk-Retention-in-CMBS https://www.trepp.com/TreppTalk/bid/333936/What-Qualifies-Ri... Some commercial loans are considered qualifying, and don't have retention requirements. The skin in the game requirement, notably, only acts as an incentive for issuers to write good loans. If they think the loans are good, but it turns out they weren't, I believe we're in the same situation. Especially with how money was essentially free, it seems like it would have been quite easy for issues to cover their retention requirements and still cover lots of real estate. The impact on banks if the loans go bad should be the same though, I believe.