April 20, 2016 Newsletter
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April 20, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


As so many of you are aware, the morning of the opening of ABS Vegas 2016 was a bitter-sweet day for the industry as it marked the passing of our inaugural Chair – Reggie Imamura, who was taken so suddenly from us by pancreatic cancer.

Reggie was a true Champion for this industry, bringing grace and honor to every situation he faced and instilling all those around him with his passion for the industry.

Please help us pay tribute to his legacy by supporting SFIG’s Team Reggie in D.C.’s PurpleStride event, where we "Wage Hope" against this deadly disease and help raise awareness and funds that advance research and support patients and loved ones with a promise of a better tomorrow.

Please sign up to be part of our team, come and cheer us on in D.C., or just simply donate to the team’s goal by visiting the Team Reggie link on the Pancreatic Cancer Action Network website here.

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SFIG’s Women in Securitization initiative is pleased to invite you to an exciting panel discussion, Women at the Intersection of Finance and Policy, on May 12th, 2016. This will be the first large-scale WiS event in the nation’s capital, and is being hosted by Morgan, Lewis & Bockius LLP at their Washington, D.C. office.

The panel will feature women with prominent roles in the federal government and the finance industry, and the discussion will cover a variety of topics including:

  • Women in government and on the Hill – how far have we come?
  • Workplace culture – how do women excel and get promoted?
  • What do leaders – both male and female – need to do to support women at all levels of an organization?

DATE: Thursday, May 12, 2016

TIME: 5:00-7:00 p.m. (ET)

LOCATION: Morgan, Lewis & Bockius LLP
1111 Pennsylvania Ave NW
Washington, DC 20004

A networking reception will follow after the panel discussion. Space is limited so please register here now. If you are not yet registered with WiS, please sign up here.

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We are thrilled to have seen very positive responses from the Canadian Issuer and Investor community for this year's Structured Finance Canada Conference.

Back in 2015, SFIG was asked by many members to initiate a new conference – a conference that was appropriately focused on a tight agenda that maximized an attendee's ability to cover relevant subject matter in a short amount of time; and a conference that was located in Toronto to minimize disruption to many of the market participants that are Toronto based or could leverage the conference together with other business rationale to be in the city over a number of days.

Early registrations and sponsorship levels tell us that we are making great progress towards these goals, with over 250 market participants, including over 150 investors/issuers already registered for the event!  

The program has been designed by Canadian market participants and is targeted to address topics of interest to investors. 

The event will kick off with an industry dinner on May 31st, followed by a full day of panels/ educational program on June 1st. The conference agenda for a full day of programming may be found here.

We look forward to seeing you in Toronto on May 31st – June 1st 2016. 

To register for Structured Finance Canada 2016, please click here.

If you are interested in sponsorship opportunities, please contact Christopher Keeping.

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Earlier this month, SFIG reported that the Office of the Comptroller of the Currency (“OCC”) issued a white paper detailing how the agency will supervise financial innovation at national backs and beyond. The white paper also describes the eight guiding principles that the OCC will follow in “handling regulation of financial technology, ranging from a commitment to better communicate with financial institutions to a pledge to work with the Consumer Financial Protection Bureau and other regulators to develop a consistent supervisory approach to fintech products.”

SFIG’s Marketplace Lending Committee will be submitting comments to the OCC’s white paper, with Mayer Brown serving as drafting counsel. Comments on the white paper are due to the OCC by May 31st, 2016.

If you are interested in joining SFIG’s Marketplace Lending Committee, please contact Jennifer.Wolfe@sfindustry.org.

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SFIG is still accepting nominations for its Board of Directors in anticipation of the June 2016 Board rotations. Eligibility for a position on the SFIG Board of Directors is limited to individuals employed by SFIG’s primary members. Members may nominate themselves or qualified industry participants.

SFIG’s Nominating Committee will review nomination submissions, consult with members and make recommendations to the current Board of Directors. The Nominating Committee is dedicated to selecting a balanced Board of Directors that is reflective of the membership and the industry at large, and is committed to working hard and advancing the principles of SFIG.

Board of Director terms are for two years. Nominations for the Board of Directors will be accepted until April 29, 2016.

If you have any questions or require any clarification around the nominating process, please email Committees@sfindustry.org

Click here to submit your nominations. Please note that the nomination form is open to registered members only. Members that have not yet registered can do so here.

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With SFIG continuing to expand its reach across new conferences and additional policy challenges we are looking for additional talent.

If you are smart, enthusiastic, hard-working, and want to be part of a growing organization in a fun and supportive environment, please contact us at jobs@sfindustry.org or visit our website at www.sfindustry.org/jobs.

Opportunities exist for a variety of experience sets, ranging from Executive/Administrative Assistant to Director of Advocacy. We look forward to hearing from you! 

 Some of the latest industry positions available include:

Enterprise Sales T-REX 03-04-2016
Associate Director/Director - Structured Finance - Model Management Fitch Ratings 02-29-2016
Research Analyst PeerIQ 02-25-2016
Credit Quant PeerIQ 02-22-2016
Mid-Level Corporate Trust Associate K&L Gates LLP 02-22-2016
Senior Analyst, Consumer ABS Kroll Bond Rating Agency 02-04-2016
Analyst, Financial Institutions Kroll Bond Rating Agency 02-03-2016
Associate Director, Structured Finance - Toronto Standard & Poor's 01-29-2016

Attorney- Project Finance/Corporates

Kroll Bond Rating Agency 01-28-2016

Analyst – CMBS Analytics

Kroll Bond Rating Agency 01-28-2016

Please visit our Jobs page for a full listing of available positions.

For questions about positions at SFIG, please contact Jobs@sfindustry.org. For questions about the website jobs portal, please contact Website@sfindustry.org.

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  • THURSDAY, April 21, 2016
    10:00 a.m. – 11:00 a.m. (ET)
  • THURSDAY, April 28, 2016
    10:00 a.m. – 11:00 a.m. (ET)

THURSDAY, April 21, 2016
3:00 p.m. — 4:00 p.m. (ET)


TUESDAY, April 26, 2016
1:00 p.m. — 2:00 p.m. (ET)


WEDNESDAY, April 27, 2016
2:00 p.m. – 3:00 p.m. (ET)

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THURSDAY, April 21, 2016
Marriott New York Downtown
New York, NY
Registration available here.

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MONDAY, May 16, 2016 – TUESDAY, May 17, 2016
Grand Hyatt New York
New York, NY
Registration available here.

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THURSDAY, May 12, 2016
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Ave NW
Washington, DC
Registration available here.

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TUESDAY, May 31, 2016 – WEDNESDAY, June 1, 2016
Hyatt Regency Toronto
Toronto, Ontario
Registration available here.

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TUESDAY, June 14, 2015 – THURSDAY, June 16, 2016
The Barcelona International Convention Centre
Barcelona, Spain
Registration available here.

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If you would like to participate in the work SFIG is undertaking through our committees as highlighted below, please e-mail Committees@sfindustry.org. For specific inquiries on any of SFIG’s advocacy efforts, please contact the staff member listed for the related project.

SFIG’s Marketplace Lending Committee was established in August 2015, as an SFIG participant committee and is open to all SFIG members who have a legitimate interest in marketplace lending. The committee was formed with two primary intentions: 1) to work with members involved in marketplace lending to educate the industry as a whole, with a particular focus on the securitization of assets generated through that lending channel; and 2) to determine appropriate securitization-specific policy and engage in related advocacy, leveraging SFIG’s prominence and experience across all asset classes to support the continued responsible growth of securitization in marketplace lending.

The committee recently launched its “Best Practices” initiative to establish industry consensus and provide recommendations around one or multiple accepted approaches. The five established Best Practices work streams are 1) Data & Reporting 2) Representations & Warranties 3) Regulatory 4) Operational Considerations and 5) Enforcement.

The committee previously commented on the Treasury Department's Request for Input on Online Marketplace Lending on September 30th.

SFIG’s Student Loan Committee recently responded to Fitch’s proposed amendments to FFELP student loan ABS rating methodology. The committee also submitted a response to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans this past October.

To join SFIG’s Student Loan Committee and learn more, please contact Alyssa.Acevedo@sfindustry.org.

The RMBS 3.0 Task Force released its Third Edition RMBS 3.0 Green Papers in November 2015. The task force has continued its efforts to address key issues specific to private label mortgage securities through work-streams relating to (1) Representations, Warranties, and Repurchase Enforcement; (2) Due Diligence, Data, and Loan-Level Disclosure; (3) Role of Transaction Parties; and (4) Bondholder Communications. We encourage members to participate in any or all of the working groups to contribute towards the mission of RMBS 3.0. For its 2016 agenda, the task force will address topics including the inclusion of an independent Deal Agent in transactions, Bondholder Communications, Data and Loan-Level Disclosure, Repurchase Enforcement, and Settlements, as well as undertake a review of the previously published Green Papers.

For additional information on RMBS 3.0, please contact Amanda.Bateman@sfindustry.org.

SFIG, through its GSE Reform Task Force, along with several other trade associations, submitted a letter to the FDIC, Fed and OCC regarding the effect of homeowner’s association ‘super-liens’ on private-label RMBS and whole loan transactions. The task force also submitted comments on FHFA’s update to the single security initiative on October 7, 2015. The task force is expecting to receive an update from the SFIG participants on the Industry Advisory Group for the Common Securitization Platform and Single-Security following its second meeting on December 7th. The task force has also formed policy positions on the Carney-Delaney-Himes GSE Reform bill and updated its briefing book to support its advocacy efforts. With the release of the bill, SFIG staff also updated its GSE Reform Legislative Comparison, which analyzes key provisions in the five most recent housing finance reform bills.

To join SFIG’s GSE Reform Task Force and learn more, please contact Amanda.Bateman@sfindustry.org.

The Mortgage Loan-Level Disclosure Task Force is studying the recent Regulation AB II release of Schedule AL and comparing it to SFIG’s Schedule L submission to the Securities and Exchange Commission in February 2014. SFIG also continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. The task force will also be conducting an analysis of the data elements included in SFIG’s Schedule L submission in order to determine any privacy concerns.

Please contact Amanda.Bateman@sfindustry.org for additional information on SFIG’s work on this topic.

The Volcker Task Force has been working with SFIG’s various asset class and legal counsel committees to identify areas within the Volcker Rule in need of clarification, particularly questions regarding covered funds and the loan securitization exemption.

Please contact Alyssa.Acevedo@sfindustry.org to participate on the Task Force.

The Risk Retention Industry Guide Working Group recently launched its interim Industry Guide, ahead of the RMBS compliance date, focused on issues either relevant to all asset classes or specific to RMBS. The Working Group continues to work on a final guide focused on creating best practices and developing consensus positions around several areas within the Credit Risk Retention final rule.

Please contact Alyssa.Acevedo@sfindustry.org with any questions.

SFIG’s Chinese Market Committee recently completed their White Paper, A Comprehensive Guide to U.S. Securitization, for Chinese regulators and the Chinese Securitization Forum to educate them on the U.S. securitization landscape. The committee also continues to hold discussions with a focus on SFIG’s partnership with the CSF, potential upcoming educational discussions and the sharing of recent market developments in China.

If you would like more information on SFIG’s work with respect to Chinese securitization, please contact Alyssa.Acevedo@sfindustry.org.

The Regulation AB II Task Force has been focused on the disclosure and offering process requirements within the final rule. Asset specific work streams have been formed to develop comment letters on the outstanding proposals within the final rule and the Task Force submitted the first part of its comment letter this past June. SFIG submitted a supplemental comment letter covering credit card and equipment floorplan asset classes on January 12, 2016.  Future discussions across asset class committees and the Regulation AB II Task Force will focus on the remaining outstanding proposed rules, including potentially requiring issuers to provide the same disclosure for Rule 144A offerings as required for registered offerings.

SFIG members who are interested in joining this task force or asset specific committees should contact Alyssa.Acevedo@sfindustry.org

The Regulatory Capital and Liquidity Committee recently submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The committee is also addressing industry concerns related to the Federal Reserve Board’s Final Rule on the Liquidity Coverage Ratio (“LCR”). This committee will also develop a comment letter when U.S. regulators release their proposed Net Stable Funding Ratio (“NSFR”). SFIG recently testified before Congress, focusing on global regulatory issues, including LCR, that affect lending across all asset classes.

To become involved in SFIG’s advocacy on the final LCR or NSFR rules, please contact Alyssa.Acevedo@sfindustry.org.

The Derivatives in Securitization Task Force obtained no-action relief from the CFTC giving swap dealers comfort that the CFTC would not take enforcement action against swap dealers that did not comply with certain CFTC Regulations when taking actions in response to the credit ratings downgrade of a counterparty to a legacy swap. The relief applies to swaps with SPVs that were in existence prior to October 10, 2013. The task force also commented on the CFTC’s proposal on margin requirements for uncleared swaps, as well as the prudential regulators’ proposal regarding margin and capital requirements for covered swap entities. In October 2015, the prudential regulators approved a Joint Final Rule on Swap Margin Requirements. In November 2015, the CFTC issued their final rule regarding margin requirements for uncleared swaps for swap dealers and major swap participants.

The High Quality Securitization ("HQS”) Task Force recently submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The task force previously responded to the European Commission’s consultation on an EU framework for simple, transparent and standardized securitization on May 12, 2015. The task force also previously responded to the BCBS-IOSCO consultation on its criteria for identifying simple, transparent and comparable securitizations. SFIG’s comments were built off of those sent to the European Banking Authority on January 14th (available here) regarding its proposed criteria and to the European Central Bank and Bank of England last summer (available here) regarding the development of a sustainable securitization market in Europe. SFIG recently testified before Congress, focusing on global regulatory issues, including HQS, that affect lending across all asset classes.

To join the HQS Task Force, please contact Alyssa.Acevedo@sfindustry.

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At a Senate Banking Committee hearing last Thursday, April 14th, Counselor to the Secretary of the U.S. Treasury Antonio Weiss and Federal Reserve Governor Jerome Powell insisted that there is neither conclusive nor compelling evidence of an extensive decline in liquidity in fixed income markets as a result of increased regulation, such as Dodd-Frank.

Weiss testified that liquidity is “well within historical levels,” despite persistent concerns expressed by some market participants to their legislators, according to a recent MarketWatch article. Despite requests from Republican senators for Weiss and Powell to point to Dodd-Frank regulations as contributing factors for market participant complaints about liquidity issues in fixed income markets, Powell was steadfast that the financial system was “safer, sounder, more resilient, and less risky” now than before the financial crisis. “Dodd-Frank regulations get the credit,” said Powell, and Weiss concurred.

Weiss attributed the recent turmoil in the fixed-income markets to several structural changes “driven by technology, changing risk appetites and business models, much-needed financial reform, and changes in the investor base” that are ongoing. However, the “core of the financial system” has been strengthened by reforms adopted in response to the crisis, according to Weiss.

This opinion is in stark contrast to SFIG’s recent testimony before the House Financial Services Committee regarding the effects of Dodd-Frank and Basel requirements on ABS liquidity. SFIG Executive Director Richard Johns stated, “We are already seeing that the new liquidity and capital rules have negatively impacted the market and reduced liquidity. There is a very real danger that these rules will restrict the supply of funding to an extent that could cause harm to important sectors of the real economy.”

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On Monday, April 18th, Senate Banking Committee Chairman Richard Shelby sent letters to the U.S. Government Accountability Office (“GAO”) and Congressional Budget Office (“CBO”) requesting Congressional reports on matters related to the Federal Housing Finance Agency (“FHFA”) and government sponsored enterprises (“GSEs”) Fannie Mae and Freddie Mac. Senator Shelby writes that recently, “FHFA has taken steps that appear to encourage a more active, rather than a reduced, role in the mortgage market for the [GSEs],” and has caused questions to be raised on this stated goal through the development of the common securitization platform. The Senator notes that the initial purpose of FHFA’s efforts, including the creation of the CSP, was to facilitate greater secondary market competition, but now it appears FHFA is no longer working towards enabling use of the CSP by other market participants.

Consequently, the Senator has asked that the GAO study and report on the extent to which FHFA’s actions could influence the GSEs dominance in the residential mortgage markets, any increase in the cost to entry for future competitors to the GSEs, the current and future demands on the Treasury, possible options for modifying the GSEs structures, and any other areas GAO finds appropriate to evaluate these issues. Of the CBO, the Senator requests a short report be commissioned which answers the following questions:

  • What are the federal government’s financial obligations to Fannie Mae and Freddie Mac while they are in conservatorship?
  • What would be the implications for the budget and the federal debt if the GSEs were to retain more of their earnings?
  • How would increasing the GSEs’ capital affect the risk borne by taxpayers? 
  • Could an increase in the capitalization of the GSEs have consequences for the operations of the GSEs or the mortgage markets?

Senator Shelby has asked that the GAO produce its report by November 1st, 2016 and that the CBO produce its report by July 1st, 2016.

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Federal Reserve Governor Lael Brainard delivered remarks last week on the potential of distributed ledger technology.

Her speech, “The Use of Distributed Ledger Technologies in Payment, Clearing, and Settlement,” explored the impact of blockchain on the U.S. financial markets. Brainard highlighted the potential innovation this emerging technology could bring to payment, clearing, and settlement activities, while also emphasizing the need to carefully analyze potential risks associated with distributed ledger technology.

Governor Brainard focused on safety, integrity and financial stability, stressing that these are critical and long-standing public policy objectives of the Federal Reserve.

According to Governor Brainard, the fundamental threshold test for new technologies will be whether they can be deployed and operated safely, with the requisite high degree of operational and financial integrity, security, and resilience across a wide range of adverse scenarios. Regulators and the public need to know that if adverse scenarios do occur, there will be robust management and governance to respond effectively.

The challenges associated with blockchain technology moving forward were also highlighted. These included scaling and achieving diffusion as well as determining how different technologies interoperate with each other.

Brainard indicated that the Federal Reserve will continue to seek to engage industry stakeholders and regulatory colleagues on issues facing blockchain technology development.

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According to a recent article in National Mortgage News, the Federal Housing Finance Agency (“FHFA”) has authorized government sponsored enterprises (“GSEs”) Fannie Mae and Freddie Mac to offer limited principal forgiveness to underwater borrowers. As stated in the article, FHFA issued guidance to the GSEs’ servicers outlining a principal-reduction program whereby borrowers who have been 90 days or more delinquent as of March 1st and have mark-to-market, loan-to-value ratios that exceed 115 percent will be eligible for relief. The program could help as many as 33,000 seriously delinquent borrowers.

National Mortgage News notes the maximum amount of principal forgiveness is 30 percent of the unpaid principal balance and if borrowers are more underwater than this amount, they may not lower their LTV to below 115 percent. Servicers will be required to furnish to eligible borrowers a solicitation letter by October 15th, 2016 detailing the terms of the modification. According to FHFA Director Mel Watt, the principal reduction program may seem "too small and too late" but it is consistent with FHFA's statutory obligation to help troubled homeowners avoid foreclosure.

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SFIG has a number of Committees and Task Forces meeting and working on many topics of interest to the securitization industry. Please email us for more information, including how to join.

SFIG is pleased to share this edition of its newsletter with our members, as well as our supporters in the structured finance community. To ensure that you receive future editions of the newsletter, please visit our website or email us to learn more about membership opportunities.

Contact Information

Richard Johns Executive Director

Kristi Leo Investor Relations

Sairah Burki Senior Director, ABS Policy

Michael Flood Director, Advocacy

Dan Goodwin Director, Mortgage Policy

Jennifer Wolfe ABS Policy Manager

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Senior Analyst, MBS Policy

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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