August 12, 2015 Newsletter
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August 12, 2015
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS

  WiS WEEK BEGINS TOMORROW

Beginning tomorrow, August 13th, SFIG encourages all industry members to celebrate our female colleagues through Women in Securitization (“WiS”) Week. From August 13th-20th, we will welcome our female colleagues to a series of regional roundtables, highlight the experience and achievements of notable industry women, and focus attention on developing solutions to some of the issues facing women in the workplace.

WiS week will provide a forum for these conversations through a series of regional roundtable discussions, hosted by SFIG members across North America. Very limited places remain, as industry women prepare to gather in New York, Chicago, DC, Charlotte and Toronto and share experiences and develop workable solutions to some of the key issues facing today’s professional women, including:

  • Professional Development & Overcoming Structural Obstacles
  • Work-Life Balance—Succeeding at Home and in the Office
  • Gender Based Perceptions on Female Potential
  • “Likeability” and Leadership—Encouraging Support for Our Female Colleagues

We encourage you to engage with your colleagues—male and female—to learn more about the experience of female professionals and think about how we as individuals and an industry can better support the retention and development of female talent throughout WiS week and beyond.

If you would like to attend a WiS week regional roundtable, sign up today as we are almost at full capacity. Attendance is open to all industry women registered for WiS.

 
 
PETITION FOR REHEARING IN MADDEN CASE DENIED

Last month, on June 26th, SFIG filed an amicus curiae brief in Madden vs. Midland on behalf of the defendant, Midland Funding LLC. The Second Circuit previously ruled that a debt buyer, which purchased defaulted credit card accounts from a national bank, is not entitled to collect interest under the National Bank Act at the rate set in the cardholder agreement. The case raised concerns about loan assets purchased in the secondary market because purchasers commonly rely on the ability to collect interest at the contract rate. SFIG engaged Sidley Austin LLP to draft this brief and SIFMA joined SFIG in its submission. Today, the petition for a rehearing in the case was denied. Midland Funding now has 90 days to ask the U.S. Supreme Court to review the Second Circuit's decision.

SFIG will be following up with next steps through our Legal Counsel Committee. If you would like to join, please contact Alyssa.Acevedo@sfindustry.org.

 
 
SFIG MEETS WITH FDIC TO DISCUSS HIGH QUALITY SECURITIZATION

On Monday, August 10th, SFIG staff and members met with officials at the Federal Deposit Insurance Corporation (“FDIC”) to discuss the implications of a High Quality Securitization ("HQS") framework in the U.S. and Europe. The meeting provided SFIG and the FDIC an opportunity to touch base subsequent to the finalization of the Basel Committee on Banking Supervision and International Organization of Securities Commission’s criteria for simple, transparent and comparable securitizations and the European Banking Authority’s recommendations to the European Commission on a European framework for HQS. SFIG welcomed the opportunity to follow up with the FDIC since last meeting in March to discuss these consultations.

For questions about the meeting, please contact Sairah.Burki@sfindustry.org. To sign up for SFIG’s HQS Task Force, please contact Amanda.Bateman@sfindustry.org.

 
 
SFIG MEETS WITH JOINT REGULATORS TO DISCUSS NSFR

Yesterday, August 11th, SFIG staff and members met with regulators from the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Federal Reserve Board to discuss members’ comments regarding the Basel Committee on Banking Supervision's final Net Stable Funding Ratio (“NSFR”) rule. The discussion focused on NSFR's treatment of ABS and MBS as well as its impact on traditional securitizations and outstanding commercial paper issued by consolidated ABCP conduits.

For questions, please contact Sairah.Burki@sfindustry.org.

 
 
INDUSTRY JOBS

Current open positions at SFIG include:

  1. Director of Mortgage Policy: will lead all initiatives related to mortgage-backed securitization. This is a high profile position within the SFIG leadership team working directly with executive management, the Board of Directors, Committee Chairs and key members of SFIG’s membership. Additional information on the position, as well as a link to the application, is available here.

  2. Communications and Media Manager: will be an integral member of SFIG staff, providing support across the whole organization and serving as a vital link between SFIG, its membership and other external audiences. Additional information on the position, as well as a link to the application, is available here.

  3. Executive/Administrative Assistant: will be responsible for supporting the Executive Director and Directors of Policy and Advocacy while directing overall front office activities, including the reception area, mail, calendar co- ordination, meeting set-up, purchasing requests and overall office management. Additional information on the position, as well as a link to the application, is available here.

Some of the latest industry positions available include:

JOB TITLE   COMPANY POSTING DATE
Associate Analyst 1   Moody’s Corporation 7-31-15
Vice President, Senior Credit Officer (ABS Surveillance)   Moody’s Corporation 7-29-15
Associate Analyst 3   Moody’s Corporation 7-28-15
Associate Analyst 1   Moody’s Corporation 7-28-15
Analyst - Representations and Warranties Specialist   Moody’s Corporation 7-28-15
Rating Team Liaison   Moody’s Corporation 7-28-15
Analyst   Moody’s Corporation 7-28-15
RMBS Analyst - Data Specialist   Moody’s Corporation 7-28-15
Analyst   Moody’s Corporation 7-28-15

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.

 
 
SFIG CALENDAR
MEETINGS
WEEKLY CREDIT CARD ISSUER COMMITTEE CALLS
  • THURSDAY, August 13, 2015
    10:00 a.m. – 11:00 a.m. (ET)

  • THURSDAY, August 20, 2015
    10:00 a.m. – 11:00 a.m. (ET)
 
 
STUDENT LOAN WORKING GROUP CALL
FRIDAY, August 13, 2015
10:00 a.m. – 11:00 a.m. (ET)
 
 
BIWEEKLY RISK RETENTION INDUSTRY GUIDE CALL
TUESDAY, August 18, 2015
11:00 a.m. – 12:00 p.m. (ET)
 
 
SFIG MEETING WITH OCC ON HIGH QUALITY SECURITIZATION
TUESDAY, August 18, 2015
Note: Closed Meeting
 
 
SFIG MEETING WITH SEC ON HIGH QUALITY SECURITIZATION
WEDNESDAY, August 26, 2015
Note: Closed Meeting
 
 
EVENTS
WOMEN IN SECURITIZATION WEEK
THURSDAY, August 13, 2015 – THURSDAY, August 20, 2015
Registration for WiS Week Roundtables available here.
 
 
IMN’s ABS EAST 2015 CONFERENCE
WEDNESDAY, September 16, 2015 – FRIDAY, September 18, 2015
The Fontainebleau
Miami Beach, FL
Registration is available here
  • Richard Johns will be speaking on the “High Quality Securitizations” panel
  • Sairah Burki will be speaking on the “Assessing The Impact of Regulatory Reform on ABS Market Liquidity” panel
  • Michael Flood will be speaking on the “Single Asset/Single Borrower CMBS” panel
  • SFIG will also be sponsoring a “Women in Securitization” panel
 
 
ASIFMA STRUCTURED FINANCE CONFERENCE 2015

WEDNESDAY, October 14, 2015 – THURSDAY, October 15, 2015

Workshop: Clifford Chance's Office, Hong Kong
Main Conference: Conrad Hong Kong, Grand Ballroom, Lower Lobby, Hong Kong

  • Sairah Burki will be speaking at the “Workshop: Developments in the US/EU Securitization and Covered Bonds Markets”
  • Richard Johns will be a discussion leader on “Simultaneous Roundtables”

More information on the conference can be found here

 
 
IMN’s INVESTORS’ CONFERENCE ON MARKETPLACE LENDING

THURSDAY, October 29, 2015
Marriott New York Downtown
New York, NY
Registration available here

 
 
SFIG & IMN’s PRIVATE LABEL RMBS REFORM SYMPOSIUM

THURSDAY, November 12, 2015
Marriott New York Downtown
New York, NY
Registration available here

 
 
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.

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's first initiative will be to respond to the Treasury Department's Request for Input on Online Marketplace Lending. Peter Manbeck and Marc Franson of Chapman and Cutler LLP are serving as drafting counsel.

Members interested in participating should contact Amanda.Bateman@sfindustry.org.

SFIG has recently formed a Student Loan Working Group to focus on and respond to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans.

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

The RMBS 3.0 Task Force released its Second Edition RMBS 3.0 Green Paper in November of 2014. Following the successful SFIG/IMN Private Label RMBS Symposium, the task force will continue 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; and (3) Role of Transaction Parties and Bondholder Communications. Presently, the task force is working on (1) developing a comprehensive compilation of representations and warranties for release in the fall of 2015 (2) a grid summarizing roles of transaction parties. We encourage members to participate in any or all of the working groups to contribute towards the mission of RMBS 3.0.

For additional information on RMBS 3.0, or to join the task force, please contact Mary.Robinson@sfindustry.org.

The GSE Reform Task Force recently reviewed a draft response to the FHFA’s update to the single security initiative. The task force also received an update from the SFIG participants on the Industry Advisory Group for the Common Securitization Platform and Single-Security. 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 including the Johnson-Crapo bill and the PATH Act. Additionally, The task force will continue to engage the Federal Housing Finance Agency on its Single-Security proposal, guarantee fee pricing and Strategic Plan for 2015-2019.

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 of 2014. SFIG also continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. We 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 Alyssa.Acevedo@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 Amanda.Bateman@sfindustry.org to participate on the Task Force.

The Risk Retention Industry Guide Work stream is 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 continues to hold discussions with a focus on SFIG’s partnership with the Chinese Securitization Forum, 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.

SFIG’s Shadow Banking Task Force has established the following agenda:

  • Leverage the predictive powers of the G20’s shadow banking initiative to determine future SFIG advocacy initiatives
  • Assess the level of regulation to which our members are already subject
  • Measure the full impact of those regulations on lending decisions and business models
  • Provide input into IOSCO, BCBS and IAIS on the revitalization of securitization markets

The task force will have its first full meeting in the coming weeks, and members from across asset classes are encouraged to participate.

To register your interest in SFIG’s Shadow Banking Initiative, please contact Amanda.Bateman@sfindustry.org.

The Regulation AB II Task Force will focus on the disclosure and offering process requirements within the final rule. Two work streams have been formed to develop a comment letter on the proposed rules that remain outstanding and to produce an industry guide for critical elements of the final rule.

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 is 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”).

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.

SFIG members who are interested in learning more about this initiative should email Amanda.Bateman@sfindustry.org.

The Money Market Fund Reform Working Group submitted a comment letter on October 13, 2014 regarding the Securities and Exchange Commission’s July 23, 2014 proposal which includes, among other things, possibly amending rule 2a-7’s issuer diversification provisions to eliminate an exclusion that is currently available for securities subject to a guarantee issued by a non-controlled person. SFIG also submitted a comment letter in September 2013 on Money Market Fund Reform.

If you are interested in joining this working group, please contact Alyssa.Acevedo@sfindustry.org.

The High Quality Securitization ("HQS”) Task Force 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.

To join the HQS Task Force, please contact Amanda.Bateman@sfindustry.org.

 
 
INDUSTRY NEWS HIGHLIGHTS
MOODY’S REQUESTS COMMENTS ON PROPOSED CMBS ENHANCEMENTS

Last week, Moody’s Investors Service announced a request for market participants to comment on three proposed enhancements to its multi-borrower large loan (“LL”) and single asset/single borrower (“SASB”) CMBS rating approach. Moody’s found that LL and SASB CMBS transactions performed at or above expectations. Accordingly, Director of Research Tad Phillip noted that the main objective of the proposed enhancements “is to realign the rating—advance rate relationship to better reflect the historical performance of transactions and our quantitative analysis of property value and income trends.”

According to the Moody’s Investors Service press release, the proposed enhancements would:

  • Help align Moody’s collateral assessments with historical performance and would apply to all North American LL/SASB CMBS transactions
  • Refine the adjustments made to those collateral assessments
  • Establish credit neutral tail period standards and rating caps during the tail period for loans that remain outstanding past the contractual loan term for transactions in Asia-Pacific, except for Japan, and Latin America

Moody’s also proposes refining adjustments to its benchmark loan to value ratios.

A full explanation of Moody’s proposed enhancements can be found here.

 
 
CHINESE PROPERTY DEVELOPERS RESTART ABS

China’s property developers are said to be returning to the ABS market after a three-year absence in light of relaxed regulations, according to a recent Reuters article.

One major developer has issued an ABS deal worth 1.5 billion yuan ($243 million) which is expected to start trading next week and attract additional parties to China’s securitization market.

Further deals could also help fulfill the property sector’s search for cheaper and more diverse sources of funding as it tackles slowing sales and squeezed margins, according to the article.

ABS issuance in China totaled $45 billion last year and is set to grow 50 to 100 percent this year, as previously forecasted by Moody's Investors Service. New issuance in the first quarter of this year was $17.7 billion.

 
 
MARKETPLACE LENDING DISCUSSION PROVIDES CLARITY TO U.S. TREASURY RFI

As the alternative lending landscape continues to grow, with new startups operating in the industry, as well as several recent securitization deals backed by assets originated by Marketplace Lenders, the industry is gaining attention from several regulatory agencies, according to an article in Crowdfund Insider. The U.S. Department of Treasury recently issued a Request for Information (“RFI”) about Online Marketplace Lending, in an effort to bring more clarity to the alternative online lending industry. As stated in the introduction of the RFI, Treasury defines Marketplace Lending as, “the segment of the financial services industry that uses investment capital and data-driven online platforms to lend to small businesses and consumers.”

As covered in the article, online lenders tend to be categorized as either balance sheet lenders, peer to peer lenders, or as bank-affiliated online lenders. In addition, several lenders have designed their models to provide affordable and specialized products for the underserved or sub-prime borrower.

While Marketplace Lenders are primarily data-driven, the article states, “as lenders we try to curb overconfidence in a data model that has not yet withstood the test of time. Data, while extremely useful in building efficiency and scale, hasn’t yet replaced human interaction.” As the alternative lending industry begins to offer its response to the Treasury RFI, several companies in the industry are also discussing best practices and have outlined steps for building transparency and fairness in the Borrower’s Bill of Rights.

SFIG will be responding to Treasury's RFI through our new Marketplace Lending Committee. If you are interested in joining, please contact Amanda.Bateman@sfindustry.org.

 
 
S&P RELEASES REPORT ON BASEL III

Last Thursday, August 6th, Standard & Poor’s (“S&P”) released a report on “Basel III’s Recent Liquidity Guidelines and How Regulatory Requirements Could Affect The Availability And Demand For Global Securitization.”

This report provides an overview of:

  • The Liquidity Coverage Ratio’s intent to ensure that banks have enough high-quality liquid assets (“HQLA”) on hand to cover net cash outflows over a 30-day stress period, and global differences in how HQLA is defined
  • Differences in which assets are included or excluded for HQLA purposes and the likely significant impact on structured finance and fixed-income investors as a whole
  • Banks' traditional role as top holders of agency/government-sponsored enterprise-backed securities and their role as one of the top five holders of municipal securities and private MBS/ABS
  • S&P’s views regarding the task of creating an international framework for assessing liquidity, appropriate capital charges, and the expectation that regulators will remain open to market input
 
 
LOWER CAPITAL REQUIREMENTS FOR INSURERS CONSIDERED KEY TO INCENTIVIZING INVESTMENT IN EUROPE

According to a recent article in Insurance Journal, European efforts to promote securitization hinges on encouraging insurers to purchase the debt by lowering capital requirements. The article states that “While the EU insurance law known as Solvency II already offers capital relief for ‘high-quality’ securitizations, investors say it’s not enough.” According to Gareth Davies, head of ABS research at JP Morgan Chase & Co. in London, “Solvency II is a major hurdle given the larger role played by insurers in the investor base than a quick read of the stats often suggests. It’s very conservative in terms of capital charges and that’s holding back a lot of potential investors.”

Insurance Journal notes that the ABS market is currently shrinking as banks have access to cheap funds from the European Central Bank, with redemptions outpacing new deals. With capital charges at their current level, it is uneconomic to issue securitizations. However, the European Banking Authority recently recommended cutting capital charges for simple, standard and transparent securitizations by an average of 25 percent and the Basel Committee on Banking Supervision has suggested that transactions meeting its own standard of high quality might also warrant capital relief.

 
 
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

Sairah Burki Senior Director, ABS Policy

Michael Flood Director of Advocacy

Jennifer Wolfe ABS Policy Manager

Mary Robinson Policy Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Policy Analyst

Daniel Tees Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Events Coordinator

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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