April 9, 2014 Newsletter
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April 9, 2014
 

SFIG News

SFIG Calendar

Advocacy Outlook

Recent Developments

Next Week in Washington

 
SFIG NEWS
SFIG MEETS WITH SECURITIES AND EXCHANGE COMMISSION ON REGULATION AB II
Following the comment deadline extension provided by the Securities and Exchange Commission (SEC) on March 28, 2014, SFIG staff and members met with the SEC to discuss key concerns with the reproposal on April 4, 2014. Topics discussed included: scope of the proposed disclosures, the interplay between securities law and privacy law, reputation risk and selective disclosure concerns. SFIG will continue to develop its Regulation AB II comment letter, which will be submitted before the April 28, 2014 comment deadline.

If you are interested in joining the Regulation AB II Task Force, please contact Alyssa.Acevedo@sfindustry.org.

 
SFIG MEETS WITH TREASURY DEPARTMENT TO DISCUSS RETURN OF PRIVATE CAPITAL TO MORTGAGE MARKET
Last Wednesday, SFIG staff and members met with Dr. Michael Stegman, Counselor to the Secretary of the Treasury for Housing Finance Policy, and other senior policy advisors to discuss Project RMBS 3.0. SFIG first provided an overview of key obstacles impacting the lack of private capital in the mortgage market, including regulatory questions and market structural hurdles impeding issuers from issuing more private label mortgage backed securities (PLS) and investors from purchasing more PLS. The majority of the meeting was focused on reviewing Project RMBS 3.0 with Treasury officials. SFIG members focused on how the project was staffed (having a diverse leadership team of members for each working group), the focus and agendas of each working group and the tasks accomplished to date. SFIG looks forward to continuing this important dialogue with the Treasury.

Project RMBS 3.0 is SFIG’s signature project to solve key issues preventing the return of private capital to the mortgage market. The project consists of three primary working groups: 1) Representations, Warranties and Repurchase Enforcement; 2) Due Diligence/Loan Review, Data and Disclosure; and 3) Role of Trustees and Bondholder Communications. We encourage members to participate in any or all of the working groups to contribute towards the mission of Project RMBS 3.0. The Role of Trustees and Bondholder Communication Working Group will be meeting live at the New York offices of Dentons on April 10, 2014. For additional information regarding Project RMBS 3.0, please contact Mary.Robinson@sfindustry.org.
 

 
SFIG UPDATES HOUSING FINANCE REFORM LEGISLATIVE COMPARISON TO INCLUDE WATERS BILL
On March 27, 2014, Congresswoman Maxine Waters, Ranking Member on the House Financial Services Committee, released the HOME Forward Act of 2014 to reform the U.S. housing finance system and wind down the Government Sponsored Enterprises (GSEs) Fannie Mae and Freddie Mac. Waters’ proposal comes on the heels of a bipartisan housing finance reform bill offered on March 16th by Senate Banking, Housing and Urban Affairs Chairman Tim Johnson (D-SD) and Ranking Member Mike Crapo (R-ID) on March 16th. Johnson and Crapo’s bill builds off of a similar piece of legislation authored by Senators Bob Corker (R-TN) and Mark Warner (D-VA). House Financial Services Committee Chairman Jeb Hensarling’s bill to reform the U.S. housing finance system, the PATH Act, passed the House Financial Services Committee on July 23, 2013.
 
SFIG has subsequently updated our legislative side-by-side comparison to provide our members with an overview of how each of the four proposals compare.

For more information on SFIG’s advocacy on GSE Reform, please refer to our website. Members who are interested in contributing to the GSE Reform Task Force moving forward should contact Amanda.Bateman@sfindustry.org.

 
SFIG HOLDS SPRING SYMPOSIUM AT FDIC
This Monday, SFIG held an FDIC Spring Symposium in order to provide a general Asset-Backed Securities and Mortgage-Backed Securities background and current outlook. Speakers, comprised of SFIG members, covered topics that included: the history of the securitization market and current structures, a current and future market outlook, regulatory issues and an update on SFIG RMBS 3.0 initiatives and GSE Reform.

The symposium also reviewed a variety of subject areas including: Collateralized Loan Obligations, Auto, Credit Card, Asset-Backed Commercial Paper and the Volcker Rule.

 
SFIG TO HOLD FIRST CANADIAN SYMPOSIUM
SFIG is holding its first Canadian Symposium in Toronto on Tuesday, April 15, 2014. The symposium, hosted by McCarthy Tétrault LLP, is designed to help SFIG members and other industry participants stay well-informed on current issues in the Canadian Securitization market.

Registration is open to the public and will be ending on April 14th. The form to register is available here.

 
SFIG CALENDAR
JOINT TRADE ASSOCIATIONS & BASEL COMMITTEE ON BANKING SUPERVISION MEETING
WEDNESDAY, April 9, 2014
9:00 a.m – 12:00 p.m. (EST)
Mayer Brown LLP
1999 K Street, NW
Washington, DC 20006
Note: Closed Meeting

 
SFIG AND FHFA MEETING
WEDNESDAY, April 9, 2014
11:00 a.m. – 12:00 p.m. (EST)
Federal Housing Finance Agency
Note: Closed Meeting to discuss GSE Reform
 
 
NSFR WORKING GROUP CALL
THURSDAY, April 10, 2014
11:00 a.m. – 12:00 p.m. (EST)
 
 
PROJECT RMBS 3.0 ROLE OF TRUSTEE/BONDHOLDER COMMUNICATION WORKING GROUP MEETING
THURSDAY, April 10, 2014
3:00 p.m. – 4:30 p.m. (EST)
Dentons
1221 Avenue of the Americas
New York, NY 10020
Please email Mary.Robinson@sfindustry.org for more information
 
 
CANADIAN SYMPOSIUM
TUESDAY, April 15, 2014
4:00 p.m. – 6:00 p.m. (EST)
McCarthy Tétrault LLP
66 Wellington Street West #5300
Toronto, ON M5K 1E6
Note: Closed to Press
Registration available here  

 
SFIG AND FHFA MEETING
WEDNESDAY, April 16, 2014
4:00 p.m. – 5:00 p.m. (EST)
Federal Housing Finance Agency
Note: Closed Meeting to discuss return of private capital in the mortgage market

 
IMN’s INVESTOR’S CONFERENCE ON CLOS AND LEVERAGED LOANS
TUESDAY, April 22, 2014 – WEDNESDAY, April 23, 2014
Marriott Marquis
1535 Broadway
New York, NY 10036
SFIG’s Director of ABS Policy, Sairah Burki, will be speaking on the “Assessing the Fallout from Volcker: Is the Bark Worse than the Bite?” conference panel
Registration available here  

 
SFIG SPRING SYMPOSIUM
WEDNESDAY, May 14, 2014
Time and Agenda to be announced
Société Générale
245 Park Avenue, New York, NY
 
 
IMN’s 2014 GLOBAL ABS CONFERENCE
TUESDAY, June 10, 2014 – THURSDAY, June 12, 2014
Barcelona International Convention Centre
Barcelona, Spain
 
 
SFIG’s BOARD OF DIRECTORS MEETING Q2’14
TUESDAY, June 24, 2014
12:00 p.m. – 5:00 p.m. (EST)
New York, NY
Note: Closed Meeting
 
 
IMN & SFIG’s ABS EAST 2014 CONFERENCE
SUNDAY, September 21, 2014 – TUESDAY, September 23, 2014
The Fountainebleau Hotel
Miami Beach, FL
 
 
IMN & SFIG’s ABS VEGAS 2015
SUNDAY, February 8, 2015 – WEDNESDAY, February 11, 2015
The Aria Resort and Casino
Las Vegas, NV
 
 
ADVOCACY OUTLOOK
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.

Regulation AB II SFIG continues to develop a response to the proposal on asset-level disclosures issued by the Securities and Exchange Commission (SEC) on February 25, 2014 (for additional details on this approach please see the staff memorandum included in the public comment file). The SEC has extended the deadline and comments are now due on April 28, 2014. SFIG will continue to hold calls in order to address key arguments included in the letter. Please contact Alyssa.Acevedo@sfindustry.org with any questions.

Project RMBS 3.0 Working Groups conduct regular meetings via conference call to address issues specific to private label mortgage securities in the following categories: 1) Representations, Warranties and Repurchase Enforcement; 2) Due Diligence/Loan Review, Data and Disclosure; and 3) Role of Trustees and Bondholder Communications. We encourage members to participate in any or all of the Working Groups to contribute towards the mission of Project RMBS 3.0. The Role of Trustees and Bondholder Communication Working Group will be meeting live at the New York offices of Dentons, on April 10, 2014. Please see the SFIG Calendar for additional information, and contact Mary.Robinson@sfindustry.org to join a Working Group or with any additional questions on Project RMBS 3.0.

The GSE Reform Task Force has formulated policy recommendations that it is reviewing within SFIG. The GSE Reform Task force held multiple calls recently to analyze the differences between the proposed Johnson-Crapo legislation and the draft positions established by the GSE Reform Task Force. These differences will form the basis of SFIG’s advocacy efforts with members of the Senate Committee on Banking, Housing, and Urban Affairs. If you would like to learn more about SFIG’s activities with respect to GSE Reform, please contact Amanda.Bateman@sfindustry.org.

The Mortgage Loan-Level Disclosure Subcommittee has reviewed and developed additional data elements for potential disclosure. SFIG will use this work as a basis of discussions and correspondence with the Securities and Exchange Commission on the mortgage aspects of Regulation AB II. SFIG continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. Please contact Alyssa.Acevedo@sfindustry.org for additional information on SFIG’s work on this topic.

The Working Group on the Canadian Proposed ABCP Disclosure is meeting via conference call to develop a comment letter in response to the Canadian Securities Administrators’ (CSA) proposed New Prospectus Exemption would require that short-term securitized products comply with a number of new conditions and disclosure requirements, including extensive disclosure of Asset Backed Commercial Paper transactions. Comments are due April 23, 2014. For more information, or to participate on this working group, please contact Mary.Robinson@sfindustry.org.

The Volcker Task Force is working with the asset class committees to determine key issues and needs for interpretative guidance regarding the Volcker Rule. Please contact Amanda.Bateman@sfindustry.org for additional information on the Volcker Task Force.

The Net Stable Funding Ratio (NSFR) Working Group is meeting via weekly conference call to develop a comment letter to reflect the concerns and positions of SFIG members regarding the proposed revisions to the NSFR. Comments are due April 11, 2014. Please see the SFIG Calendar for additional information on the NSFR Working group call, and email Mary.Robinson@sfindustry.org with any questions on the NSFR proposal or Working Group.

The Risk Retention Committee is continuing to follow up with regulators on risk retention questions across asset classes. Topics currently under discussion include participations, representative sample and the alternative to simplified approach. Please contact Alyssa.Acevedo@sfindustry.org with any questions.

SFIG is continuing to build membership for its Chinese Market Committee and is currently looking to establish committee chairs as well. If you would like more information on SFIG’s work with respect to Chinese securitization, please contact Alyssa.Acevedo@sfindustry.org.

SFIG has launched its initiative to provide critically needed input for the Financial Stability Board’s “Shadow Banking” project. For more information on SFIG’s work on Shadow Banking, please contact Amanda.Bateman@sfindustry.org.

 
RECENT DEVELOPMENTS
AGENCIES ADOPT ENHANCED SUPPLEMENTARY LEVERAGE RATIO FINAL RULE AND ISSUE SUPPLEMENTARY LEVERAGE RATIO NOTICE OF PROPOSED RULEMAKING
On April 8, 2014, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency adopted a final rule to strengthen the leverage ratio standards for the largest, most interconnected U.S. banking organizations.

The final rule applies to U.S. top-tier bank holding companies with more than $700 billion in consolidated total assets or more than $10 trillion in assets under custody (covered BHCs) and their insured depository institution (IDI) subsidiaries. Covered BHCs must maintain a leverage buffer greater than 2 percentage points above the minimum supplementary leverage ratio requirement of 3 percent, for a total of more than 5 percent, to avoid restrictions on capital distributions and discretionary bonus payments. IDI subsidiaries of covered BHCs must maintain at least a 6 percent supplementary leverage ratio to be considered "well capitalized" under the agencies' prompt corrective action framework. The final rule, which has an effective date of January 1, 2018, currently applies to eight large U.S. banking organizations that meet the size thresholds and their IDI subsidiaries. The final rule is substantively the same as the rule proposed by the banking agencies in July 2013.

The banking agencies also issued a notice of proposed rulemaking (NPR) that would modify the denominator calculation for the supplementary leverage ratio in a manner consistent with recent changes agreed to by the Basel Committee on Banking Supervision. The revisions in the NPR would apply to all internationally active banking organizations, including those subject to the enhanced supplementary leverage ratio final rule. Comments on the NPR are due on June 13, 2014.

 
CONGRESS QUESTIONS FED’S TWO-YEAR EXTENTION OF CLO DEADLINE FOR VOLCKER CONFORMANCE TO JULY 21, 2017
On Monday, the Federal Reserve Board extended the deadline for banking entities to conform their ownership interests in and sponsorship of collateralized loan obligations (CLOs) to the Volcker Rule by two years to July 21, 2017. Per the Federal Reserve’s press release, “A banking entity would not have to include ownership interests in CLOs to determine its investment limits under the final rule, and a banking entity would not be required to deduct CLO investments from tier 1 capital under the final rule until the end of the relevant conformance period.”

On Tuesday, the House Financial Services Committee held a hearing to examine the consequences of recent rulemakings by the federal regulatory agencies on “consumers, community financial institutions, the U.S. economy and our domestic job creating businesses.” Important to SFIG members, regulators were questioned by Members of Congress on the two-year extension for CLO conformance to the Volcker Rule.

Scott Alvarez, General Counsel for the Federal Reserve Board, stated during the hearing that the Federal Reserve reviewed call sheets, and found that approximately $105 billion of the $300 billion in outstanding CLOs are owned by roughly 50 banks. Further, 90 percent of that total are owned by a handful of large banks.

Alvarez further stated that the Fed’s two-year extension would help solve 50 percent of the CLOs outstanding as they will come due by the 2017 conformance period. The two extra years would also help these 50 banks to either divest or conform the remaining 50 percent of CLOs to the Volcker Rule.

“Your solution may minimize the problem for 50 percent of the loans, but it does not solve the problem,” stated Congressman Peter King (R-NY). “Why not grandfather all legacy CLOs that are currently on bank balance sheets?”

In response, Alvarez stated that the Volcker rule “does not allow or contain a provision to allow the (regulatory) agencies to grant an exception for grandfathering or an exception to allow banks to avoid losses.”

SFIG will be following up with our members, the regulators and Congress to determine next steps. Please contact Amanda.Bateman@sfindustry.org to participate in SFIGs CLO Task Force.
 
 
BANK OF ENGLAND REGULATOR DISCUSSES RISKS POSED BY ASSET MANAGEMENT INDUSTRY
In a recent speech at the London Business School conference on asset management, Bank of England executive director of financial stability, Andrew Haldane, addressed the risks to the financial system that might be posed by non-banks, including asset managers as well as the associated policy implications. According to the speech, asset management serves as a key bridge between end-savers and end-borrowers and as such need to be regulated in a manner similar to banks.

Haldane emphasized the size of the asset management industry, noting Assets Under Management (AUM) are currently estimated at around $87 trillion globally, and that it has grown rapidly, roughly doubling over the past decade. In the U.S. in particular, AUM have risen from around 50 percent of GDP to around 240 percent since 1946, and this trend is similar across all Organisation for Economic Co-operation and Development countries, as their populations grow larger, older and richer. According to one estimate, AUM is forecasted to top the $100 trillion mark by 2020. Given the size and growth of the industry, Haldane stated that “asset management may not only come of age – we may be about to enter the Age of Asset Management.”

The scale of the industry and its evolving structure have led Haldane to question whether it poses similar risks as banks that are “too-big-too-fail.” He subsequently suggested three areas that should be targeted in any policy response to “deal with the risks and opportunities posed by asset management.” First, he noted work that is currently underway internationally to help identify whether asset managers should be classified as globally systemic financial institutions. Included among these efforts is that of the U.S. Financial Stability Oversight Council targeting shadow banking. Second, he argued that “macro-prudential action may be justified even when leverage is not present and when banks are not at the scene of the crime.” Finally, he described initiatives underway to encourage the financing of long-term investment, including work on securitization where the market is being “helped by public and private sector initiatives to improve transparency.” The Bank of England intends to support the ongoing international work to create a “high-quality” securitization product which “might comprise simpler structuring of payoffs and high and transparent underwriting standards.” According to Haldane, so-designed, such a lower risk securitization might benefit from preferential regulatory treatment.

 
EUROPEAN UNION PUSH TO REVITALIZE SECURITIZATION
Support for a higher quality securitization categorization has been increasing in recent weeks within the European Union. In a separate speech on Monday, European Central Bank executive board member Yves Mersch stated that “the revised securitization framework should reflect the risk-mitigating features of high quality securitization. It is therefore important that the EU moves ahead swiftly in addressing inconsistencies in the treatment of high quality securitization.” In that speech, Mersch suggested there is room to maneuver when deciding what treatment to grant, including adjusting supervisory parameters in the current securitization proposals or adopting straightforward preferential risk weights in a similar manner to covered bonds in the Capital Requirements Regulation.

As non-bank asset management continues to face increased scrutiny on an international scale as well as in the U.S. from the Financial Stability Oversight Council, SFIG will step up our efforts to engage regulators on matters relating to shadow banking. Members interested in contributing to this newly emerging area of SFIG’s advocacy agenda should email Amanda.Bateman@sfindustry.org.

 
SENATE MOVES TO EXTEND MORTGAGE DEBT FORGIVENESS IN TAX BILL
On April 3rd, the Senate Finance Committee passed the Expiring Provisions and Improvement Reform and Efficiency Act (EXPIRE Act) by voice vote to extend provisions of the tax code by two years, retroactive to January 1, 2014. Included in the tax provisions is the Mortgage Debt Forgiveness Relief Act, which relieves homeowners of the requirement to pay taxes on any mortgage debt forgiveness they receive resulting from mortgage modifications or short sales.

The EXPIRE Act would extend 45 tax provisions in total, and cost $85 billion over 10 years. The bill is now expected to pass the Senate with a strong bipartisan vote, and then head to the House for consideration.

 
GARRETT RELEASES BILL TO IMPROVE FSOC TRANSPARENCY
On April 3rd, Congressman Scott Garrett, Chairman of the Financial Services Committee’s Subcommittee on Capital Markets and Government-Sponsored Enterprises, released H.R. 4387, the Financial Stability and Oversight Council (FSOC) Transparency and Accountability Act. The bill is intended to correct what he calls “the most egregious and indefensible concerns about transparency and accountability at the FSOC.” H.R. 4387 was released days after the Congressman was denied a request to attend the FSOC’s most recent meeting and a day after Securities and Exchange Commissioner Luis Aguilar expressed similar concerns about its transparency.

The FSOC was created under the Dodd-Frank Act to monitor systemic risks following the recent financial crisis. Garrett’s bill would subject the FSOC to the Government in the Sunshine Act and Federal Advisory Committee Act; allow participation of all members of the Commissions and Boards represented at all FSOC meetings; require that any vote taken by the principal of a Commission or Board represented must first be taken by that Commission or Board and the principal must then in turn vote that same decision at the Council; and allow for Members of Congress on the Congressional oversight committees of FSOC to be able to attend all FSOC meetings.

 
GINNIE LIMITS FIXED-RATE HOME EQUITY CONVERSION MORTGAGES
According to an article in American Banker, Ginnie Mae (Ginnie) is declaring its reverse mortgage securitizations off-limits to a new type of product that could require the servicer to take interest rate risk. After May 31, 2014, the agency will no longer allow its pools to include fixed-rate Home Equity Conversion Mortgages (HECMs) that distribute some of their proceeds as a line of credit. The use of these loans has been in response to rule changes at the Federal Housing Administration, which insures HECMs, the predominant reverse mortgage program. Not allowing these HECMs in Ginnie securitizations is likely to hamper the product's growth, since there are few other secondary marketing options for reverse mortgages. Ginnie is apparently concerned about these fixed-rate credit lines because if interest rates rise, the servicer may be on the hook to finance additional draws at a higher cost.
 
 
OTC DERIVATIVES REGULATORS ISSUE PROGRESS REPORT TO G-20
On March 31, 2014, the Over-the-Counter (OTC) Derivatives Regulators Group (ODRG) issued a report to the G-20 on the remaining cross-border implementation issues related to global reform of OTC derivatives markets. The report summarizes each of the issues and provides a timetable for addressing them through a series of reports to the G20 Finance Ministers and Central Bank Governors over the course of 2014.

The ODRG report cites the treatment of branches and affiliates and organized trading platforms and implementation of trading commitments as the two cross border issues the group is working to develop approaches to address. They are additionally working to implement understandings reached in the areas of equivalence and substituted compliance, clearing determinations, risk mitigation techniques for non-centrally cleared derivatives transactions (margin), and data in trade repositories. Finally, the issues being monitored by the ODRG are those identified as appropriate for other fora or bilateral engagement including: risk mitigation techniques for non-centrally cleared derivatives transactions (non-margin), access to registrant’s books and records and barriers to reporting to trade repositories. The report notes there has been bilateral progress between ODRG members with respect to organized trading platforms and cooperative oversight.

The next report on the progress of OTC derivatives reform by the ODRG will be for the September 2014 Finance Ministers and Central Bank Governors meeting. It will include an update on the progress made with respect to the issues outlined in the recent report and will be followed up with a report in November providing a similar update.

The ODRG is comprised of authorities with oversight of OTC derivatives markets in Australia, Brazil, the European Union, Hong Kong, Japan, Ontario, Quebec, Singapore, Switzerland and the United States.

 
FHFA RELEASES FORECLOSURE PREVENTION RESULTS
The Federal Housing Finance Agency stated in a report that Fannie Mae and Freddie Mac have completed more than 3.1 million foreclosure prevention actions since the start of conservatorship in 2008. FHFA stated these actions have helped more than 2.5 million borrowers stay in their homes, including nearly 1.6 million who received permanent loan modifications. During 2013, Fannie Mae and Freddie Mac completed nearly 448,000 foreclosure prevention actions, 99,700 of these in the fourth quarter.

 
NEXT WEEK IN WASHINGTON
SEC INVESTOR ADVISORY COMMITTEE MEETING
THURSDAY, April 10, 2014
10:00 a.m. – 4:00 p.m. (EST)
Securities and Exchange Commission's Headquarters Multi-Purpose Room, Washington, DC
Contact: DonleyO@SEC.GOV

 
HOUSING AND URBAN DEVELOPMENT BUDGET HEARING
THURSDAY, April 10, 2014
10:00 a.m. (EST)
House Appropriations Subcommittee on Trasnportation, Housing & Urban Development, and Related Agencies
2358-A Rayburn House Office Building
A webcast of the hearing will be available on the House Appropriations Committee website.  

 
OCC BANK DIRECTOR WORKSHOP
MONDAY, April 28, 2014 – WEDNESDAY, April 30, 2014
Embassy Suites Baltimore-Inner Harbor, Baltimore, MD
Three-day workshop designed exclusively for directors of institutions supervised by the Office of the Comptroller of the Currency. The workshop will provide practical information on the roles and responsibilities of a community bank director.
 
 
JOHNSON-CRAPO HOUSING FINANCE REFORM BILL MARKUP
TUESDAY, April 29, 2014
10:00 a.m. (EST)
Senate Banking, Housing, and Urban Affairs Committee
534 Dirksen Senate Office Building
A webcast of the markup will be available on the Senate Banking, Housing & Urban Affairs Committee website.
 

SFIG COMMITTEES AND TASK FORCES

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

Sonny Abbasi Director of MBS Policy

Sairah Burki Director of ABS Policy

Michael Flood Director of Advocacy

Mary Robinson Senior Policy Analyst

Alyssa Acevedo Policy Analyst

Amanda Bateman Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Executive Administration


1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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