August 19, 2015 Newsletter
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August 19, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


SFIG is pleased to announce that Common Securitization Solutions (“CSS”), Fannie Mae and Freddie Mac will provide an update on the implementation of the Common Securitization Platform (“CSP”) and Single Security to its membership on Monday, August 24th at 4:00 p.m. (ET). Speakers providing the update include:

  • David Applegate, Chief Executive Officer, Common Securitization Solutions
  • Renee Schultz, Senior Vice President of Capital Markets, Fannie Mae
  • Richard Sorkin, Senior Vice President of Securitization, Fannie Mae
  • Steve Clinton, Senior Vice President of Strategic Initiatives, Freddie Mac
  • Mark Hanson, Senior Vice President of Securitization, Freddie Mac

Robert Fishman, Senior Associate Director, Office of Strategic Initiatives, Federal Housing Finance Agency, will also join the call.

On July 8th, Fannie Mae, Freddie Mac and CSS jointly announced that SFIG would participate in a newly created Industry Advisory Group to provide feedback and share information on efforts to build the CSP and implement the Single Security. Monday’s update will expand SFIG’s participation in this process by informing the membership of the progress to-date on implementing the two initiatives.

To learn more about the CSP and Single Security, please click here. To read an overview of the CSP, please click here. To read SFIG’s views on the CSP and Single Security, please click here and here.

If you would like to participate on the call, please register here (note: you must be logged in to access the form). To join SFIG’s GSE Reform Task Force and contribute to advocacy on this topic, please contact


Yesterday morning, August 18th, the U.S. Department of the Treasury extended the deadline to submit comments in response to its Request for Information (“RFI”) on Public Input on Expanding Access to Credit Through Online Marketplace Lending by 30 days to September 30, 2015.

SFIG’s goal is to deliver a response to the RFI which reflects the key perspectives of its diverse membership, especially as it relates to securitization and the alignment of interests between marketplace lenders, originators, and investors. The extension will allow SFIG’s diverse membership to provide meaningful insights to the RFI. SFIG thanks the Department of the Treasury for extending the comment period through the end of the summer period.

To view the extension of the comment period, please click here. To view SFIG’s request for the extension, please click here. To participate in SFIG’s Marketplace Lending Committee and its response to the RFI, please contact


On Tuesday, August 18th, SFIG staff and members met with officials at the Office of the Comptroller of the Currency (“OCC”) to discuss the implications of a High Quality Securitization ("HQS") framework in the U.S. and Europe. The meeting provided SFIG and OCC officials an opportunity to discuss 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.

For questions about the meeting, please contact To sign up for SFIG’s HQS Task Force, please contact



As WiS Week draws to a close tomorrow, SFIG would like to thank the attendees and hosts for helping make the regional roundtables a great success. Each session reached registrant capacity and the strong turn-out helps signify the importance of these events to our industry. Across North America, the women of structured finance gathered to discuss real life challenges and workable solutions to various hurdles professional women encounter.

Three final regional roundtables in New York, Charlotte, and Toronto are being held tomorrow. Registration for these events has reached capacity and is now closed. We look forward to continuing the dialog well past the conclusion of formal WiS Week activities, and further involving the industry in this important initiative.

We hope that you’ve taken an opportunity to get to know some of our industry women, and acquaint yourselves with the issues WiS Week is addressing through our daily bulletins. Stay tuned for highlights of the week in tomorrow’s release.

To stay up-to-date on WiS activities or get more involved in the initiative, please register here. Contact for more information.


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 coordination, 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:

Senior Vice President, RMBS Monitoring   Moody's Corporation 8-18-15
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
Capital Markets Associate   Cadwalader, Wickersham & Taft LLP 7-21-15
Director - Credit Process Management   Fitch Ratings 7-09-15
Associate Director / Director, Asset Backed Securities   Fitch Ratings 7-08-15
Mid-level Asset Securitization Associate Attorney   Chapman and Cutler LLP 7-01-15

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

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

  • THURSDAY, August 20, 2015
    10:00 a.m. – 11:00 a.m. (ET)

  • THURSDAY, August 27, 2015
    10:00 a.m. – 11:00 a.m. (ET)
MONDAY, August 24, 2015
2:00 p.m. – 3:00 p.m. (ET)
WEDNESDAY, August 26, 2015
2:00 p.m. – 3:00 p.m. (ET)
WEDNESDAY, August 26, 2015
Note: Closed Meeting
THURSDAY, August 13, 2015 – THURSDAY, August 20, 2015
Registration for WiS Week Roundtables available here

MONDAY, August 24, 2015
4:00 p.m. - 5:00 p.m. (ET)
Registration available here

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

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 "Developments in the US/EU Securitization and Covered Bonds Markets” workshop
  • Richard Johns will be a discussion leader at the “Impact of European Regulation (AIFMD, CRD II/IV, CRA3) and US Regulation (Volker, Dodd-Frank and Commodity Pool Operator)" roundtable

More information on the conference can be found here


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


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


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'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

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

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

The GSE Reform Task Force reviewed a draft response to the FHFA’s update to the single security initiative earlier this month. 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

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

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

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

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

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

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

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


Earlier this month, Shellpoint brought an RMBS transaction to the market that included features in its representation and warranty framework that align with the best practices developed through SFIG’s RMBS 3.0 initiative. With this transaction structure, Shellpoint is the first issuer to include a modification trigger and an optional insolvency trigger. This Shellpoint deal, SCOT 2015-1, is the first to incorporate specific recommendations from SFIG’s 3.0 framework into a transaction taken to market.

To view SFIG’s RMBS 3.0 Second Edition Green Papers, please click here. To join SFIG’s RMBS 3.0 initiative, please contact


Last week, on August 6th, a U.S. Court of Appeals ruled in the case of Madden vs. Midland Funding LLC that it would not reconsider a decision to prohibit lenders from bypassing state usury laws by partnering with banks in states where such limits do not exist. A recent article in Bloomberg explains, “The ruling effectively would stop a practice whereby lenders can make a loan to a borrower in, say, New York—where interest rates are capped at 16 percent for most loans—by originating it in Utah, which has no usury limits.” As a result, lenders may be forced to lower interest rates charged to certain borrowers and some existing loans may be deemed in violation of state interest-rate caps.

Unless lenders are successful in requesting a review by the U.S. Supreme Court, the decisions could be detrimental to loans already packaged into securities and hinder future originations, as high-yielding credits currently enjoy strong investor demand. Bloomberg cites an August 4th presentation by LendingClub, in which the marketplace lender—currently the largest in the industry—estimated that approximately 12.5 percent of its consumer-loan portfolio may be affected by the decision.

The ruling was handed down by the U.S. Court of Appeals in Manhattan and is binding in New York, Connecticut and Vermont. However, the business practices of marketplace lenders in particular will likely face continued scrutiny from market participants as well as lawmakers, as evidenced by the request for information on marketplace lending underway at the U.S. Treasury Department.


The European Commission (“EC”) is considering letting short-term asset-backed commercial paper (“ABCP”) qualify for preferential capital treatment, according to a recent Bloomberg article. This consideration is part of an effort to revive the European ABS market in response to prompting from banks and asset managers.

The European Union (“EU”) plans to make ABCP with an original maturity of a year or less eligible for the “simple, transparent and standardized” label that will open the door to capital relief. When the EC originally proposed its high-quality ABS plan back in February, it stated that “[t]he criteria of the delegated acts...are designed for medium to long-term securitisation instruments (i.e. asset-backed securities). They do not cover short-term securitisation instruments especially asset-backed commercial paper.” However, the EC also sought views on whether to include ABCP for the first time and many in the industry argued that admitting ABCP would benefit corporate lending. SFIG also advocated for the development of ABCP criteria in our response to the EC’s Consultation

The European Commissioner for Financial Stability, Financial Services and Capital Markets Union, Jonathan Hill, proposed the ABS overhaul and promised to deliver an "action plan" next month followed by "a comprehensive package on securitization."


Fannie Mae and Freddie Mac’s latest quarterly results show that the government-sponsored enterprises (“GSEs”) still dominate the mortgage industry, according to an article in National Mortgage News. “Over 50% of all mortgages are sold to Fannie and Freddie” said Rick Roque, managing director of retail lending at Michigan Mutual. The article highlights several key takeaways from the GSEs’ second-quarter financial results.

First, competition between the GSEs has been increasing as Freddie looks to catch up with Fannie by growing its single-family mortgage securities business. The GSEs’ financial results also show that recent profits have been concentrated in guarantee-fee revenues and refinancing activity. As stated in the article, “more than 40% of Freddie’s net interest income in the second quarter was derived from management and G-fees.”

Delinquency rates dropped at the end of June giving the GSEs’ fewer liabilities on their books. While Fannie and Freddie have been trying to loosen credit standards and revive past programs, regulatory mandates are putting more emphasis on risk-sharing initiatives with the private sector. Although Fannie and Freddie have a regulatory mandate to shrink, the combined value of their portfolio of mortgage assets shows that the industry still heavily relies on the GSEs.


Recently ABS has been impacted by the expected rate hikes, liquidity and tactical concerns, according to an article in Bloomberg. The current spread in ABS shows that several market segments are near post-crisis wides established in 2009. Referring to car loans to prime-credit borrowers, the article states, “spreads on AAA rated one-year securities tied to that debt reached 0.32 percentage point last week, their widest level since late 2009, according to Wells Fargo.” Industry analysts see the spreads as being influenced by liquidity rather than credit conditions, as top-rated securities are being affected rather than deals with more risk. Bank of America analysts Chris Flanagan, Theresa O’Neill and Elana Lipchak said, “[s]ome of the securities that are holding up best include those backed by subprime auto loans, private student loans and certain esoteric transactions.”


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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