August 11, 2016 Newsletter
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August 11, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


As previously highlighted, SFIG will be hosting a series of updates on some of the most current and pressing advocacy issues facing the securitization market and how the industry is responding at ABS East 2016 on Sunday, September 18th from 12:30 p.m. – 4:30 p.m., Track C. Advocacy efforts to be covered include RMBS 3.0, Reg AB II and marketplace lending. Investor closed-door roundtable discussions will also be held, covering Market Liquidity and the SFIG Investor advocacy agenda.

Below is the complete agenda:

SUNDAY, September 18, 2016
Track C

12:30pm – 1:15pm:
RMBS 3.0 – Returning Private Capital to the Mortgage Market
          Daniel Goodwin & Eric Kaplan

1:15pm – 2:00pm: Marketplace Lending
          Jennifer Wolfe & William Black

2:15pm – 3:00pm:
Q4 2016 SFIG Investor Agenda and 2017 agenda
          Kristi Leo & SFIG Investor Cabinet

3:00pm – 3:45pm:
Investor Liquidity Review – The Path Forward
          Kristi Leo & SFIG Investor Cabinet

3:45pm – 4:30pm: Reg AB/Disclosure
          Alyssa Acevedo & Charles Sweet

Please note these sessions require advanced attendance which may be confirmed with Lucy Springett at

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On August 5, 2016, SFIG submitted a response to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation, collectively, the “Agencies,” on the proposal entitled “Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements” released on April 26, 2016. 

The letter proposes adjustments relating to both parts of the NSFR – the numerator (available stable funding) and the denominator (required stable funding).

SFIG previously commented on the Basel Committee on Banking Supervision’s NSFR proposal on April 11, 2014. To become involved in SFIG’s advocacy on NSFR rules or related matters, or to join the Regulatory Capital & Liquidity Committee, please contact

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Yesterday, August 10th, SFIG was pleased to welcome nearly 150 participants who joined our educational webinar entitled “Blockchain 101: Revisiting the Basics.”

Industry experts from Deloitte, including Lisa Hernandez, Senior Manager, Dzmitry Maroz, Senior Manager, and Prakash Santhana, Managing Director, provided a review of the key fundamentals of blockchain technology during the webinar.

SFIG members can access a video of the webinar recording here.

At the start of the summer, SFIG launched a Blockchain Symposia Series to educate industry participants, and build an understanding of how blockchain works and how the technology may be applied to enhance and support the structured finance market. Our additional symposium events will take place on October 4th in New York City and October 6th in Washington D.C.

If you are interested in joining SFIG’s Blockchain Task Force, please contact

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SFIG Positions

Are you or someone you know eager to join a supportive, hard-working and fun nonprofit team doing incredible work? Good news, SFIG has several openings! Please see the below job opportunities and help us spread the word by passing them along to anyone who might be a good fit:

  • Director of Education: will be responsible for the strategic development and execution of a comprehensive and robust in-person and online education and member development program.
  • RMBS/CMBS Policy Manager: will contribute to the design of, and help execute group-wide strategy efforts and initiatives in support of SFIG’s mortgage policy priorities.
  • Manager of Advocacy: will design and execute advocacy strategies, engage with Capitol Hill and federal regulatory agencies as well as support SFIG’s advocacy efforts through development and growth of its political action committee.
  • Policy Analyst: will support general policy initiatives and investor relations through direct member engagement, meeting facilitation, research and analysis.

You can also follow our Twitter @SFIndustryG at to stay updated on all SFIG job opportunities.

Industry Positions

Some of the latest industry positions available include:

Analyst/Associate Director - Asset Backed Securities Fitch Ratings 07-15-2016
Director/Senior Director - Asset Manager Leader Fitch Ratings 05-03-2016
Director/Senior Director - Research and Criteria Leader Fitch Ratings 05-03-2016

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

Current members are encouraged to advertise open positions within their company on SFIG's website by filling out the form here.

For questions about positions at SFIG, please contact For questions about the website jobs portal, please contact

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WEDNESDAY, August 17, 2016
4:00 p.m. – 5:00 p.m. (ET)

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THURSDAY, August 18, 2016
10:00 a.m. – 11:00 a.m. (ET)

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WEDNESDAY, August 24, 2016
2:00 p.m. – 3:00 p.m. (ET)

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SUNDAY, September 18, 2016
3:00 p.m. – 5:00 p.m. (ET)
Eden Roc Hotel, Ocean Garden
Miami Beach, FL
Registration forthcoming

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SUNDAY, September 18, 2016 – TUESDAY, September 20, 2016
The Fontainebleau
Miami Beach, FL
Registration available here.

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SUNDAY, February 26, 2017 - WEDNESDAY, March 1, 2017
Aria Resort & Casino
Las Vegas, NV
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 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 30, 2015.

SFIG’s Student Loan Committee responded to Fitch’s proposed amendments to FFELP student loan ABS rating methodology earlier this year. The committee also submitted a response to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans in October 2015.

To join SFIG’s Student Loan Committee and learn more, please contact

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

In response to a request for public comment issued by FHFA on the GSEs’ credit risk transfer processes, SFIG, through its GSE Reform Task Force, convened a call on July 7th to gauge membership’s interest. The task force is currently working on a response to be submitted no later than August 29, 2016.

To join SFIG’s GSE Reform Task Force and learn more, please contact

The Mortgage Loan Level Disclosure Task Force will soon begin its review of the Mortgage Industry Standards Maintenance Organization’s (MISMO) work to map the data elements that lenders should deliver in securitizations per the recent Regulation AB II release of Schedule AL. The requirements will come into effect in November 2016, and SFIG has participated in weekly conference calls with MISMO for the last 18 months in an effort to standardize disclosure by that time. SFIG encourages subject-matter experts from member organizations to participate in its review—which will be conducted jointly by this task force and the RMBS 3.0 Due Diligence, Data and Disclosure Working Group—so the work can be adopted as an industry-wide standard.

Members interested in participating should contact

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 to participate on the Task Force.

The Risk Retention Industry Guide Working Group 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 with any questions.

SFIG’s Chinese Market Committee completed their White Paper, A Comprehensive Guide to U.S. Securitization, in April 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

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 in June of 2015. SFIG submitted a supplemental comment letter covering credit card and equipment floorplan asset classes on January 12, 2016 and another supplemental comment letter regarding asset-level information for student loans on June 15, 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

The Regulatory Capital and Liquidity Committee recently submitted a response to the U.S. proposed net stable funding ratio (NSFR) requirements. The committee also recently submitted comments to the Federal Reserve Board’s (FRB) proposal regarding Single-Counterparty Credit Limits, and before that, submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The committee and will be addressing industry concerns related to the FRB’s Final Rule on the Liquidity Coverage Ratio (LCR). SFIG testified before Congress in February 2016, 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

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 14, 2016 (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 testified before Congress in February 2016, focusing on global regulatory issues, including HQS, which affect lending across all asset classes.

To join the HQS Task Force, please contact

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On Monday, August 5th, Moody’s Investors Services published a report that “provides more detail on its modeling inputs and illustrates the sensitivity of its model results to certain inputs for its proposed approach to rating rental fleet securitizations.” This report follows a recent Request for Comment (RFC) from Moody’s regarding their proposed approach to rating rental fleet securitizations. The deadline for comments has been extended to September 12, 2016.

"This report provides a description of the assumptions, a base scenario, and greater details on the sensitivity analysis we will undertake using a hypothetical rental fleet pool," says Moody's Associate Managing Director, Luisa De Gaetano. "This extension will also provide additional time for market participants to review this illustration, along with other aspects of our RFC."

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According to a recent Time article, the underlying blockchain technology that powers bitcoin transactions has the potential to transform how Wall Street does business.

Time recently spoke with the CEO, Adam Ludwin, of Chain, a startup specializing in blockchain systems for assets like corporate securities. Mr. Ludwin explained in detail how blockchain technology could make financial transactions faster, cheaper, and more secure by changing clearing and settlement processes. 

Mr. Ludwin also explained the challenges that Wall Street firms may face in its blockchain adoption and suggested that the correct question that institutions should be asking is “what role do we want to play in that new network model?” Change across the market and who is leading that charge should be the focus.

If you would like to join SFIG’s Blockchain Task Force, please contact

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The first U.S. CMBS deal designed to comply with the Risk Retention rule has been priced by three major Wall Street banks, according to a recent Reuters article. Each bank owns a slice of each class from AAA to unrated, attracting investors.

"In theory the banks will support the bonds, and you might see trading in blocks be much easier," said one portfolio manager. "But I think also (it was due to) a trend of more bank-originated collateral, rather than the potpourri of originators that throw whatever they have into the deal."

The banks also included two additional safeguards to the deal. The first of which is a new risk retention “consultation party” to consult with the servicers on any workouts of soured loans, and an enhancement that will call on a deal’s trustee to order an independent “fair value” appraisal on a property if a servicer opts to sell a defaulted property out of the trust, according to Reuters.

If you are interested in joining SFIG’s CMBS Committee, please contact

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On August 4th, the Consumer Financial Protection Bureau (CFPB) issued its final rule for mortgage servicers, requiring servicers to provide certain foreclosure protections more than once over the life of a loan and clarifying protections to borrowers when a loan’s servicing is transferred.

According to a Reuters article, the CFPB stated that its amended regulation “[ensures] that homeowners and struggling borrowers are treated fairly by mortgage servicers and that no one is wrongly foreclosed upon,” and reinforces safeguards currently in place to prevent homeowners from receiving inadequate information on refinancing options.

Most provisions in the final rule will take effect 12 months after its publication in the Federal Register, which is expected soon. Some provisions, such as those related to successors in interest and periodic statements for borrowers in bankruptcy will take effect 18 months after publication in the Federal Register.

The CFPB also issued an interpretive rule under the Fair Debt Collection Practices Act (FDCPA) relating to servicers’ compliance with certain mortgage servicing provisions.

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On Tuesday, August 9th, Senator Bob Corker (R-TN) again called for the reform of government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, following their failure of a Federal Housing Finance Agency (FHFA) stress test. The test indicated that in the event of a “Severely Adverse” economic scenario, the GSEs would need to draw an estimated $125.8 billion from the limited and defined pool of capital provided by the Treasury. As of December 2015, the GSEs had already drawn $187.5 billion from the pool of capital which was originally outlined in the Senior Preferred Stock Purchase Agreements.

The release notes that in June of 2013, Sen. Corker and Sen. Mark Warner (D-VA) introduced legislation which would have wound down the GSEs, replacing them with a privately capitalized system aimed at reducing risks to taxpayers. Recent legislative proposals related to GSE reform have failed to gain traction.

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The Bank of England’s (BoE) recent announcement that it will deploy an “exceptional” stimulus package in order to revamp the real economy – amounting to approximately $100 billion – may slow the issuance of RMBS, according to a recent Bloomberg article.

BoE Governor Mark Carney’s Term-Funding Scheme (TFS) is geared towards reducing borrowing costs across-the-board, Bloomberg explains. However, a study conducted by Bank of America analysts has concluded that the TFS program slows the issuance of RMBS, further depriving investors of higher rates of return.

The TFS program succeeds the BoE’s Funding for Lending Scheme which was designed to cut borrowing costs for households and companies.

Bank of America analysts also noted that the deployment of RMBS serves as much-needed funding sources for pensions and various commercial real estate but could shrink as a result of lowered interest. TFS "pushes the overall need to return to securitization markets further into the future, so U.K. RMBS issuance is likely to stay low for longer," said the analysts.

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The Federal Deposit Insurance Corporation (FDIC) recently announced that they are seeking comments to proposed guidance regarding third-party lending. The proposed third-party lending guidance outlines the risks that may be associated with third-party lending as well as the expectations for a risk-management program, supervisory considerations, and examination procedures related to third-party lending. The comment period for this proposal has been extended to October 27, 2016.

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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

Dan Goodwin Director, Mortgage Policy

Tom McCrocklin Director, Advocacy

Jennifer Wolfe Manager, ABS Policy

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Marshall Bornemann, Policy Analyst

Robert Robilliard, Data and Policy Analyst

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

Dani Hernandez Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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