August 26, 2015 Newsletter
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August 26, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


Today, August 26th, SFIG staff and members met with representatives from the U.S. Securities and Exchange Commission (“SEC”) to discuss high quality securitization (“HQS”). Among other things, SFIG shared concerns regarding reported draft European legislation that would establish an EU framework for simple, transparent and standardized securitization (“STS”) and integrate the criteria into the Capital Requirements Regulation and Directive by granting capital relief to qualifying transactions. As SFIG communicated to the SEC, the development of an STS framework in Europe risks bifurcating markets.  The Basel Committee on Banking Supervision and International Organization of Securities Commissions are also working to determine if and how to operationalize their own framework at a global level.

For questions about the meeting, please contact To join the HQS Task Force, which will be reconvening next week to discuss the recent regulatory meetings, please contact


On Monday, August 24th, SFIG held a conference call with representatives from Common Securitization Solutions (“CSS”), Fannie Mae and Freddie Mac, who provided an update on the implementation of the common securitization platform (“CSP”) and the Single-Security. Speakers providing the update included:

  • 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 at the Office of Strategic Initiatives, Federal Housing Finance Agency, also joined the call.

SFIG would also highlight that both members and non-members will have the opportunity to hear further developments on the CSP and Single-Security at ABS East, as the aforementioned presenters will keynote the conference, with SFIG’s Executive Director, Richard Johns as the moderator.  To register for ABS East, please click here.

SFIG would like to thank CSS, Fannie Mae and Freddie Mac for providing the update to its membership, and for their participation at ABS East.

To read SFIG’s views on the CSP and Single-Security, please click here and here. To join the GSE Reform Task Force and contribute to SFIG’s related advocacy, please contact


SFIG will hold a symposium on marketplace lending in Washington, DC, followed by a cocktail reception, on Tuesday, October 6, 2015. The event will be hosted by Champan and Cutler LLP. The symposium will consist of a panel discussion including both policymakers and industry practitioners to discuss the different business models in the marketplace lending industry. The full agenda will be forthcoming.

The event is open to Congressional staff, regulators, policymakers, and SFIG members and non-members, however seating is limited. Please note, this event is closed to the press. Please click here to register.


SFIG will hold its fall symposium, followed by a cocktail reception, on Thursday, October 8, 2015. The event will be hosted by PricewaterhouseCoopers at their New York City office. The Symposium will consist of a briefing on the High Quality Securitization proposals and a panel discussion on Marketplace Lending. The full agenda will be forthcoming.

The event is open to both members and non-members, however, preference will be given to members as seating is limited. Please note, this event is closed to the press. Please click here to register.


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:

Consumer ABS Analysts   Kroll Bond Rating Agency, Inc. 8-19-15
Senior Vice President, RMBS Monitoring   Moody’s Corporation 8-18-15
Associate Analyst 1   Moody’s Corporation 7-29-15
Vice President, Senior Credit Officer (ABS Surveillance)   Moody’s Corporation 7-31-15
Associate Analyst 3   Moody’s Corporation 7-29-15
Associate Analyst 1   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

FRIDAY, August 28, 2015
1:30 p.m. – 2:30 p.m. (ET)
  • THURSDAY, August 27, 2015
    10:00 a.m. – 11:00 a.m. (ET)

  • THURSDAY, September 3, 2015
    10:00 a.m. – 11:00 a.m. (ET)
FRIDAY, August 28, 2015
12:00 p.m. – 1:00 p.m. (ET)
MONDAY, August 31, 2015
2:00 p.m. – 3:00 p.m. (ET)
TUESDAY, September 1, 2015
11:00 a.m. - 12:00 p.m. (ET)
TUESDAY, September 1, 2015
2:00 p.m. - 3:00 p.m. (ET)
WEDNESDAY, September 2, 2015
2:00 p.m. - 3:00 p.m. (ET)
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

TUESDAY, October 6, 2015
5:30 – 8:00 p.m. (ET)
Chapman and Cutler LLP
1717 Rhode Island Avenue NW
Washington, DC 20036
Please click here to register. Full agenda will be forthcoming.

Please note, this event is closed to the press


THURSDAY, October 8, 2015
5:00 – 8:00 p.m. (ET)
PricewaterhouseCoopers LLP
300 Madison Avenue
New York, NY 10017
Please click here to register. Full agenda will be forthcoming.

Please note, this event is closed to the press


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 on 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. The deadline of which was recently extended to September 30th. 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


According to an article in Bloomberg, a recent May ruling by the U.S. Appeals Court in Manhattan is threatening to remove a protection that non-bank lenders have used to make high-interest loans. As stated in the article, “[t]he issue boils down to whether these lenders can pay a bank in an unregulated state to make loans to borrowers in other jurisdictions, where the interest rates could be considered usurious.”

The ruling in Madden vs. Midland Funding LLC, which is binding in New York, Vermont and Connecticut, is putting pressure on lenders to change the way they originate debt and could force them to lower interest rates. Several banks are easing back their support in debt sales because they say that lowering interest rates may make the debt less attractive to investors who are willing to finance risky loans. However, while banks are concerned with lending money for which there is no secondary market, according to Chief Executive Officer Renaud Laplanche of LendingClub, the recent ruling is not impacting Lending Club’s ability to finance its business. “We continue to see sufficient appetite from investors for loans in New York, Connecticut and Vermont,” said Laplanche. If the recent ruling is heard by the Supreme Court and upheld, it could have a significant impact on loans that may be in excess of state interest rate limits. 


Last Wednesday, August 19th, the European Banking Authority (“EBA”) announced that it will now incorporate additional analysis into its calibration reports on Net Stable Funding Ratio (“NSFR”) and Leverage Ratio.

The European Commission had previously requested further advice in order to ensure any possible future policy actions are well-informed. Specifically, it was requested that the EBA conduct further analysis on proportionality, the scope of application and impact on markets of the calibration of NSFR and Leverage Ratio. The EBA will be incorporating these aspects into its reports to the maximum extent possible, as well as taking into account the constraints in data availability.

The EBA is required to develop a calibration report on NSFR by the end of this year and on the Leverage Ratio by October 2016 (however, the EBA reported this is likely to be advanced to July 2016).


According to a recent Financial Times article, the European Commission (“EC”) will soon publish draft legislation that grants capital relief to securitizations qualifying as simple, transparent and standardized (“STS”). The legislation includes two bills, one establishing a European framework for STS securitizations and a second bill that amends regulatory capital treatment in Regulation No. 575/2013 (the “CRR”), the EU rule which promulgates the Basel Committee on Banking Supervision's (“BCBS”) standards on capital.

EC legislation lowering the capital requirements for STS transactions has been expected for some time, with Commissioner Jonathan Hill telling lawmakers in Brussels in early June a proposal was forthcoming (see SFIG’s report on the hearing here). The idea has gained traction since the EC’s initial consultation on a framework this past Spring, with the European Central Bank (“ECB”) and Bank of England (“BoE”) encouraging the move and the European Banking Authority publishing technical advice to the EC in July, which the EC notes it has adopted in its amendment to the CRR.

While initially expected to reject calls for issuer self-certification—a key operational question in its consultation—the EC appears to have taken comments from the EBC-BoE and the industry, including SFIG, to heart. The STS draft legislation states:

As regards compliance with the STS criteria the most suitable mechanism identified is to ensure liability rests with originators and investors, reinforced by supervisory oversight… an ex-ante regulatory involvement of supervisors stating that a securitization meets the STS criteria would shift the responsibility to public authorities leading to moral hazard risks, whereas originators, sponsors and SSPE’s should take responsibility.

It remains to be seen how the EU framework will play out on a global level. The BCBS and International Organization of Securities Commissions recently finalized their own criteria for simple, transparent and comparable securitizations, which “are not, of themselves, a prescription for regulatory action” but are expected to be incorporated into the BCBS’s securitization framework finalized last December.

On that matter, the EC notes:

[t]he harmonization of the existing legal framework at EU level can by itself not standardize all processes and practices in securitization markets. For that reason the proposal calls upon market participants to work on further standardization of market practices.


According to an August 18th Standard and Poor’s press release, a new report entitled China Securitization: Linking International Investors And Renminbi Assets found that “international investors are focusing more on renminbi (“RMB”) assets in China, primarily to seek opportunities for asset allocation diversification and the higher returns offered by a prospering economy.”

The report highlights how “[o]ngoing improvements in processes, self-governance, and information transparency, as demonstrated in the securitization market, are likely to help support the development of the capital market.”

Standard and Poor’s Credit Analyst Vera Chaplin indicated that:

More than 140 billion RMB in securitization transactions was issued under the two major securitization schemes in China in the first six months of 2015…The transactions reveal a standardized platform for asset collections and how to allocate assets' economic value, the disclosure of more information so that risks could be analyzed, and the isolation of asset sellers' credit risk. As a result, international investors now have an opportunity to reach economic sectors that in the past they could not because of the smaller scale of the issuers or the difficulty involved in finding the value of the assets.


According to an article on, several obstacles may impair the ability to refinance the volume of CMBS set to mature between now and 2017. Rating agencies anticipate that the the obstacles to refinancing will include a need for additional capital and potential higher interest rates.

As stated in the article, “the balance of Fitch-rated loans for 2015 will see another $10.8 billion in maturities across 1,215 loans…this year’s total will be dwarfed by both 2016 and 2017, with a total of $119 billion in Fitch-rated CMBS coming due over those two years.” For this year’s remaining maturities, the largest property type concentration is in retail, followed by office and multifamily.


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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