August 4, 2016 Newsletter
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August 4, 2016
 
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
REMINDER: REGISTER NOW FOR SFIG’s EDUCATIONAL WEBINAR ON BLOCKCHAIN TECHNOLOGY

At the start of the summer, SFIG launched a Blockchain Symposia Series to educate industry participants, and build an understanding of how blockchain works and how the technology may be applied to enhance and support the structured finance market. As part of our commitment to both education and advocacy, we are excited to announce the next event in our series:

SFIG’s Educational Webinar on Blockchain Technology
“Blockchain 101: Revisiting the Basics”

Wednesday, August 10th at 11:00am ET

Register
here now!

This webinar will build upon the content of our Blockchain Symposia Series, with educational insight into the key fundamentals of blockchain technology. The additional symposium events will take place on October 4th in New York City and October 6th in Washington D.C.

After registering for the webinar, you will receive a confirmation email containing information about joining.

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INDUSTRY JOBS

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 https://twitter.com/SFIndustryG to stay updated on all SFIG job opportunities.


Industry Positions

Some of the latest industry positions available include:

JOB TITLE COMPANY POSTING DATE
Analyst/Associate Director - Asset Backed Securities Fitch Ratings 07-15-2016
Senior Manager, Securitization Platform: Liquidity and Funding Manager – 126543BR TD Bank 06-24-2016
Principal - Structured Product Group (RMBS) PGIM 05-04-2016
Director/Senior Director - Data and Operations Leader Fitch Ratings 05-03-2016
Director/Senior Director - Research and Criteria Leader Fitch Ratings 05-03-2016
Director/Senior Director - Asset Manager 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 Jobs@sfindustry.org. For questions about the website jobs portal, please contact Website@sfindustry.org.

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SFIG CALENDAR
MEETINGS
EQUIPMENT ISSUER COMMITTEE CALL

MONDAY, August 8, 2016
2:00 p.m. – 3:00 p.m. (ET)

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RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, August 9, 2016
11:00 a.m. – 12:00 p.m. (ET)

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AUTO ISSUER COMMITTEE CALL

WEDNESDAY, August 10, 2016
2:00 p.m. -3:00 p.m. (ET)

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WEEKLY CREDIT CARD ISSUER COMMITTEE CALL

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

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EVENTS
SFIG'S EDUCATIONAL WEBINAR ON BLOCKCHAIN

WEDNESDAY, August 10, 2016
11:00 a.m. – 12:00 p.m. (ET)
Registration available here.

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WOMEN IN SECURITIZATION (WiS) SPECIAL EVENT AT ABS EAST 2016

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

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IMN’s ABS EAST 2016 CONFERENCE

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

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SFIG VEGAS 2017 CONFERENCE

SUNDAY, February 26, 2017 - WEDNESDAY, March 1, 2017
Aria Resort & Casino
Las Vegas, NV
Registration available here.

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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 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 in September 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 Alyssa.Acevedo@sfindustry.org.

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 Marshall.Bornemann@sfindustry.org.

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

To join SFIG’s GSE Reform Task Force and learn more, please contact Marshall.Bornemann@sfindustry.org.

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 Marshall.Bornemann@sfindustry.org.

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 Alyssa.Acevedo@sfindustry.org 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 Alyssa.Acevedo@sfindustry.org 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 Alyssa.Acevedo@sfindustry.org.

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 Alyssa.Acevedo@sfindustry.org

The Regulatory Capital and Liquidity Committee will be developing a comment letter 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 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. In October 2015, the prudential regulators approved a Joint Final Rule on Swap Margin Requirements. In November 2015, the CFTC issued their final rule regarding margin requirements for uncleared swaps for swap dealers and major swap participants.

The High Quality Securitization (HQS) Task Force recently submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The task force previously responded to the European Commission’s consultation on an EU framework for simple, transparent and standardized securitization on May 12, 2015. The task force also previously responded to the BCBS-IOSCO consultation on its criteria for identifying simple, transparent and comparable securitizations. SFIG’s comments were built off of those sent to the European Banking Authority on January 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 Alyssa.Acevedo@sfindustry.org.

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INDUSTRY NEWS HIGHLIGHTS
CFPB RELEASES PROPOSAL TO OVERHAUL DEBT COLLECTION MARKET

Last Thursday, July 28th, the Consumer Financial Protection Bureau (CFPB) released an outline proposal that aims to “increase protections pertaining to third-party debt collectors and others covered by the Fair Debt Collection Practices Act, including many debt buyers.” The CFPB has stated that it plans to address consumer protection issues involving first-party debt collectors and creditors on a separate track as part of its overhaul of the debt collection marketplace. Specifically, the new protections within the proposal are aimed at ensuring that debt collectors: collect the correct debt; limit excessive communications; make debt details clear and disputes easy; document debt on demand for disputes; stop collecting or suing without proper documentation; and stop burying the dispute.

As part of their review process, the CFPB has also released a report entitled “Study of Third-Party Debt Collection Operations.”

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HOUSE DEMOCRATS SEND LETTER TO CFPB IN SUPPORT OF ARBITRATION RULE

On Wednesday, August 3rd, a letter signed by 65 House Democrats was sent to CFPB Director, Richard Cordray, underscoring their strong support for the Bureau’s proposed rule to prohibit the use of class-action waivers in arbitration agreements for financial services products. The group, led by Reps. Maxine Waters (D-CA), Ranking Member of the Committee on Financial Services; John Conyers, Jr. (D-MI), Ranking Member of the Judiciary Committee; and Hank Johnson, Jr. (D-GA), voiced concern that without the rule, arbitration clauses "enable corporations to avoid public scrutiny by precluding access to the courts.” The letter bases this argument on findings from a CFPB study which it claims “unequivocally demonstrates that the proposed rule is necessary to the public interest and consumer welfare.”

The CFPB issued its proposed rule in early May and has since begun receiving public comment on it. Its release represents the culmination of the nearly six year period since the agency was directed to study arbitration and propose rules based on its findings by the 2010 Dodd-Frank Act.

SFIG will be submitting a response highlighting the significant concerns that our members have with this proposal. If you are interested in joining the working group for this comment letter, please contact Jennifer.Wolfe@sfindustry.org.

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CFPB’S TRID UPDATE, MOVES IN THE RIGHT DIRECTION BUT ISSUES REMAIN

According to an American Banker article, while resolving some key issues for mortgage lenders the Consumer Financial Protection Bureau (CFPB) has done little to address what steps lenders should take to “correct errors” in disclosure documents. While there was significant progress in resolving questions of disclosure related to co-ops, certain loan guaranty programs, and issues related to disclosure timing the article goes on to state that, “the biggest disappointment is that the bureau did not provide more guidance on how lenders correct errors, an issue that has held up the sale of loans to secondary market participants and prompted repeated calls for more clarity.” Instead, Agency personnel state that “the mortgage industry should rely on Truth in Lending Act’s provisions for cures of technical violations.”

While the CFPB continues its monitoring of Know Before You Owe (or TRID), a mortgage compliance rule designed to increase transparency between lenders and borrowers, the agency falls short in bridging the gap for secondary market lenders in addressing concerns over liability.

SFIG plans to meet with the CFPB to discuss the new proposal, which is open for comment until October 18, 2016.

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HILLARY CLINTON COMES OUT IN SUPPORT OF FINANCIAL TRANSACTION TAX

According to a recent Financial Times article, Presidential Nominee Hillary Clinton’s economic policy advisors are developing a proposal for a new financial transaction tax (FTT). This news follows the recent inclusion of a general call for an FTT in the Democratic Party platform. An early outline of Clinton’s plan suggests that it would levy a fee on canceled orders in an attempt to curb practices by high frequency traders.

In contrast, more liberal members of the Democratic Party have called for an FTT which would encompass a much broader set of transactions. In the past, Sen. Bernie Sanders has sponsored legislation which "specifies a 50 basis point tax on equity trades, a 10bp tax on bond trades, and a one-half basis point tax on derivatives transactions."

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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

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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