August 18, 2016 Newsletter
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August 18, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


Get ready for a boat racing at the WiS Miami Regatta, poolside at the Eden Roc Hotel's Ocean Garden!

Join us for an afternoon of networking with fellow industry members! Women and men are welcome at this fun-filled event, where there will be:

  • The Regatta – boat-racing in the pool...need we say more? With an appearance by a special guest commentator and multiple prize winning opportunities
  • Lawn games including bean bag toss and ladder ball
  • A make-your-own mojito bar
  • WiS Career Sponsorship program launch

Calling on Senior-level Women and Men in Securitization: Come and take the pledge to become a Career Sponsor!

This program provides female and male executives the opportunity to take an active role in sponsoring the careers of individual high-potential women within, or outside of, their organizations. We urge industry leaders and those with influence at senior levels within your organization to become a Career Sponsor for a woman in securitization.

To learn more, join us at the WiS Miami Regatta at ABS East!

To register for this event and sign up to race a boat, please click here.

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On Tuesday, August 16th, SFIG held a call for SFIG investors and representatives from Moody’s Investor Services to discuss, in detail, explanations around the proposed changes within the recent Request for Comment (RFC) regarding rating rental fleet securitizations. Moody’s RFC outlines proposed revisions to assumptions regarding vehicle disposal values, fleet composition and sponsor probability of default, among others. Comments to the RFC are due by September 12th.

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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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TUESDAY, August 23, 2016
11:00 a.m. – 12:00 p.m. (ET)

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

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WEDNESDAY, August 24, 2016
4:00 p.m. – 5:00 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 available here.

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SUNDAY, September 18, 2016
12:30 p.m. – 4:30 p.m. (ET)

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

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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 October 13, 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 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 submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations in February 2016. 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 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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According to a Business Insider article, the World Economic Forum (WEF) has concluded that blockchain technology “will fundamentally alter the way financial institutions do business around the world.”

The WEF’s study entitled “The future of financial infrastructure,” said blockchain technology “has great potential to drive simplicity and efficiency" in financial services and "will redraw processes and call into question orthodoxies that are foundational to today's business models…and will help build innovative solutions across the industry, becoming ever more integrated into the structure of financial services, as mainframes, messaging services, and electronic trading did before it."

The WEF, and collaborator Deloitte, spent 12 months putting together this report and talked to almost all of the world's top investment banks, central banks around the world, and startups, according to Business Insider.

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

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According to a Fitch press release, U.S. credit card ABS are performing nicely, with monthly payment rates (MPRs) on the upswing.

Prime card metrics have been positive. The 60-day and above delinquencies have decreased to less than a percent at 93 basis points. The delinquency index is 2.11 percent below last year’s level and also well lower than the 4.54 percent peak that was reached in December 2009. As for the MPR, the tally is at 30.31 percent, up 85 basis points and at an historic high.

Similarly, the retail credit index saw MPRs grow to 16.56 percent for the month of July. The gross yield has also been on an upswing, and the total is up more than 6 percent over the previous year.

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Results of a global survey conducted by Deloitte show that “nearly half of big banks around the world” are not ready for a new International Financial Reporting Standard known as IFRS 9, set to come into effect in 2018. More details from the results of the survey have been reported in the Financial Times, which states that  the “poll of 91 banks across the globe — excluding U.S. banks that are governed by their own rules — has found that 46 percent of those surveyed do not believe they have enough resources to deliver changes by the 2018 implementation date.” Further, a “significant minority” of the banks also stated that they could not find enough skilled talent in the marketplace to hire in order to accomplish the required changes.

In terms of the impact the rules will have on banking institutions, “nearly two thirds of banks are unsure how the rules might impact their balance sheets,” and for banks that have calculated the impact, they “reckon the rules will result in a surge of at least 25 percent in total impairment provisions across all asset classes.” The new rules will bring changes to the way loss provisioning worked prior to the financial crisis, in that it will “force banks to have a provision on their balance sheets for expected losses in the future rather than actual losses already suffered.”

Additionally, the banks surveyed are forecasting that the new rules “will cause their capital ratios to deteriorate: they are expecting core tier one capital — one of the most keenly watched metrics of the health of a bank’s balance sheet — to decrease on average by half a percent as a result of moving to the new standard” according to Deloitte. But banks are not the only financial institutions that are experiencing uncertainty in the face of the new rules, “99 percent of respondents said their local financial regulator had yet to say how they might incorporate IFRS 9 numbers into regulatory capital requirements.”

IFRS 9 is just one part of a “suite of measures by the International Accounting Standards Board to overhaul accounting since the financial crisis.” The creation of international accounting rules attempts to “increase regulatory cooperation between the U.S. and international standard setters.”

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U.S. asset-backed commercial paper (ABCP) market interest rates have jumped in recent weeks, according to a Wall Street Journal article.

The rate on 90-day ABCP spiked to 0.97 percent last Wednesday before slipping back down to 0.91 percent on Thursday, according to the Federal Reserve. That is the highest level recorded since 2009.

90-day paper has experienced the most upward pressure due to pending money market rules that come into effect on October 14th. The rules require prime funds to implement temporary suspensions of customer redemptions in a crisis, resulting in customers moving their money out of prime funds and into funds that invest only in debt of the U.S. government and government sponsored entities, according to the article.

It is further noted that as a result, prime fund managers have been shortening the maturities of their portfolios in order to increase their ability to handle such redemptions, putting upward pressure on the yields of short-term debts with maturities that fall around or after the October 14th implementation date.

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Fitch Ratings finalized its criteria for rating RMBS backed by Non-Performing Loans (NPL), according to a press release by the rating agency. Fitch assumes a 100 percent probability of default and has applied a ratings cap of “Asf” to NPL RMBS due to “idiosyncratic and adverse-selection risk.” The criteria can be found on the agency’s website here.

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According to an American Banker article, consumers and industry advocates worry that vague language — as it relates to borrowers’ foreclosure protection rules — could increase operational costs for servicers.

Quyen Truong, a partner at Stroock & Stroock & Lavan LLP in Washington, D.C., underscored the rule’s increased costs, and said “All of the amendments are intended to give the borrower more opportunity for loss mitigation, and that could result in additional review and accommodation costs on the servicer or lender as well.”

Operational costs tend to rise ahead of major rule implementations. Some of the changes have a 12-month implementation timeline, while others have an 18-month implementation. The last major servicing rule implementation boosted operational expenditures to a post-crisis high in 2013 as servicers worked to have the changes made in time for an early 2014 deadline, according to data from the Mortgage Bankers Association.

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On Tuesday, August 16th, Moody’s Investor Services published its approach to rating Chinese RMBS transactions using the Moody’s Individual Loan Analysis (MILAN) framework. Moody’s indicated that they will use the MILAN approach in conjunction with their existing methodologies to rate RMBS in China.

As Moody’s explains, MILAN is “a key element of its loan and portfolio level evaluation. The calibration of MILAN for China was primarily driven by benchmarking the Chinese residential real-estate market to other jurisdictions that also use MILAN. [Moody’s] has used many parameters from the “New Securitization Market” settings of MILAN for Chinese residential mortgage pools with a few changes to reflect Chinese-specific elements.”

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Brexit may be delayed until late 2019 as new departments prep for negotiations, according to a recent Bloomberg article. The Brexit and international trade ministries are still in the process of recruiting staff, making it unlikely the Britain will invoke Article 50 — after which the country has 2 years to leave the European Union — until late next year, Bloomberg says.

Brexit minister David Davis has recruited less than half of the staff needed, adding speculation that the departments will not be ready before upcoming European elections, the article explains.

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On Thursday, August 11th, Attorneys General from 18 States and the District of Columbia sent a letter to the CFPB, stating their support for the Bureau’s recent proposed arbitration clause rule. The CFPB proposal would limit the use of mandatory arbitration clauses in consumer financial services contracts.

In their letter, the Attorneys General wrote that they support the rule because it would “restore significant and much-needed consumer protections that have been eroded through the inclusion by financial services companies of mandatory arbitration clauses in their contracts with consumers.” The letter also suggests several changes to the rule. It requests that the CFPB adjust one of its provisions so that in addition to covered entities being required to submit initial claim filings and written awards in arbitration proceedings to the Bureau, the information be made public on the bureau’s website. The letter also recommends that the CFPB impose deadlines for the reporting of such materials, enforced by strict penalties.

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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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