December 9, 2015 Newsletter
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December 9, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


Last night, SFIG’s Women in Securitization (“WiS”) initiative welcomed almost 100 industry women to its first professional development skills workshop. Led by Michelle Friedman of Advancing Women's Careers LLC, the workshop provided attendees with tools and strategies to make building and deepening professional relationships more effective and enjoyable. At the conclusion of the workshop, WiS members joined in a reception and the opportunity to connect with their industry colleagues. 

WiS thanks all of the participants for making the evening a success and extends a special thanks to Mayer Brown for hosting the event.

On Monday, December 7th, Fannie Mae, Freddie Mac (“GSEs”) and Common Securitization Solutions (“CSS”) held the second meeting of the Common Securitization Platform / Single-Security Industry Advisory Group (“CSP/SS”). The meeting provided another opportunity for the industry to engage with CSS and the GSEs as they work through their multi-year project to implement the CSP/SS.

SFIG Executive Director Richard Johns along with Keith Bickel of Bank of America, Raghu Kakumanu of Wells Fargo and Faith Schwartz of CoreLogic attended the meeting on behalf of the membership.

SFIG will hold a call with its GSE Reform Task Force in the near future to provide a download of the meeting to the membership. To join the task force, please contact

To view SFIG’s press release on the creation of the Industry Advisory Group, please click here. To learn more about the CSP and Single Security initiatives, please click here. For questions regarding SFIG’s participation in the Industry Advisory Group, please contact


On Thursday, December 3rd, Representatives Andy Barr (R-KY) and David Scott (D-GA) introduced H.R. 4166, the Expanding Proven Financing for American Employers Act (“Act”). The bipartisan bill creates a workable risk retention regime for collateralized loan obligations (“CLOs”).

Specifically, the Act creates a risk retention obligation that applies to “qualified” CLOs that meet criteria across six categories that are designed to enhance the alignment of interest between CLO managers and investors.

SFIG, in its letter to the bill co-sponsors, urged further Congressional support for H.R. 4166. “The Act is a common sense solution that will allow the CLO industry to continue supporting real economy growth through investment in local businesses and communities, while also remaining true to the goals of risk retention,” stated SFIG Executive Director Richard Johns.

To learn more about SFIG’s advocacy efforts on H.R. 4166, please contact


SFIG currently has two open positions for:

  • 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.

  • 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:

Head of US Primary Structured Credit Ratings   Moody’s Corporation 11-18-15
Associate Analyst 2   Moody’s Corporation 11-02-15
Senior Vice President, RMBS Monitoring   Moody’s Corporation 11-02-15
Vice President, Senior Credit Officer   Moody’s Corporation 11-02-15
CLO Legal Analyst   Moody’s Corporation 11-02-15
Lead Ratings Analyst – Asset Backed Securities Group (Student Loans)   Moody’s Corporation 11-02-15
Senior Vice President Operational Risk Assessment Analyst   Morningstar Credit Ratings, LLC 10-29-15
High Yield - Legal Analyst   Babson Capital Management 10-22-15
Finance Associate   Hogan Lovells US LLP 10-09-15
Attorney - Securitization   Ford Motor Credit Company 9-29-15

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, December 10, 2015
    10:00 a.m. -11:00 a.m. (EST)
  • THURSDAY, December 17, 2015
    10:00 a.m. -11:00 a.m. (EST)

THURSDAY, December 10, 2015
11:00 a.m. – 12:00 p.m. (EST)


FRIDAY, December 11, 2015
1:00 p.m. – 2:00 p.m. (EST)


MONDAY, December 14, 2015
9:00 a.m. – 10:00 a.m. (EST)


MONDAY, December 14, 2015
2:00 p.m. – 3:00 p.m. (EST)


TUESDAY, December 15, 2015
11:00 a.m. – 12:00 p.m. (EST)


SUNDAY, February 28, 2016 – WEDNESDAY, March 2, 2016
The Aria Resort & Casino
Las Vegas, NV
Registration is 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. For its first initiative, the committee commented on the Treasury Department's Request for Input on Online Marketplace Lending. The comments were submitted on September 30th and drafted by counsel at Chapman and Cutler LLP.

Members interested in participating should contact

SFIG’s Student Loan Committee will be responding to Fitch’s proposed amendments to FFELP student loan ABS rating methodology. The committee also recently responded to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans.

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; and (3) Role of Transaction Parties and 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

SFIG, through its GSE Reform Task Force, along with several other trade associations, submitted a letter to the FDIC, Fed and OCC regarding the effect of homeowner’s association ‘super-liens’ on private-label RMBS and whole loan transactions. The task force also submitted comments on FHFA’s update to the single security initiative on October 7, 2015. The task force is expecting to receive an update from the SFIG participants on the Industry Advisory Group for the Common Securitization Platform and Single-Security following its second meeting on December 7th. 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. The task force 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 Working Group 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

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


Speaking at an industry conference on Friday, December 4th, Treasury Department Counselor Antonio Weiss discussed the need for comprehensive housing finance reform. According to Weiss, while the state of the housing market has improved post-crisis and the Administration has been using all available tools to improve access to credit and housing outcomes, housing finance reform “remains the great unfinished business of financial reform” seven years later.

Weiss reiterated the Administration’s core principles behind housing finance reform, including providing broad access to long-term, fixed rate lending for all communities through all economic cycles; limiting taxpayer exposure to an explicit, appropriately-priced guarantee to ensure against catastrophic risk; and maintaining a level playing field for community banks and credit unions. While some have argued for a “recap and release” approach to resolving the Fannie Mae and Freddie Mac (“GSEs”) conservatorship, Weiss argued that “the bottom line is that we must take on the challenge of much more fundamental reform, and not settle for the misguided call to return to a deeply flawed system.” While GSE reform legislation remains pending, Weiss championed administrative actions including winding down their legacy investment portfolio, increasing credit risk sharing transactions and building the Common Securitization Platform that will issue a single GSE security.


As reported in an American Banker article last week, more than 20 mortgage related trade groups “are urging Congress to provide a hold-harmless period” until February 2016 from any errors associated with implementation of new TILA-RESPA Integrated Disclosure, or TRID, requirements. Although the CFPB has provided for an informal grace period for implementation, the article explains that “lenders, title companies and appraisers are concerned that CFPB's grace period will not protect them from liability.”  The trade groups’ letter to House members urges that "Congress should recognize this risk and protect industry from regulatory and civil liability risk as it makes good-faith efforts to comply with the many new TRID requirements".  

The letter includes a request to “House Speaker Paul Ryan, R-Wis., to include the bill in budget legislation that would likely clear the Senate and be signed by the President Obama.” This letter comes in the wake of October activity when the “House passed a Homebuyer Assistance Act by a 303-121 vote that would delay enforcement of new TRID mortgage disclosures for a few months.” The legislation has not yet been approved by the Senate.


Last Thursday, December 3rd, the European Central Bank (“ECB”) announced that it will be extending its asset purchase program by six months, a decision that will “add €680 billion – some 6.5 percent of the euro area GDP – in liquidity to the system by 2019…” according to ECB President, Mario Draghi, during a recent speech. He also stated that “this will strengthen our forward guidance on interest rates and ensure that liquidity will remain very supportive in the long term.”

This extension by the ECB, which left its monthly spending amount for asset purchases unchanged, along with its decision to cut deposit rates to negative 0.3 percent, disappointed some market participants who believe these moves to be the bare minimum in light of the bank’s previous hints that more stimulus was urgently needed, according to a recent Reuters article. Market participants originally expected a 25 percent increase in monthly asset purchases and possibly even a deeper rate cut.


Last Thursday, December 3rd, Moody’s announced a Request for Comment entitled “Moody’s Approach to Rating Chinese RMBS” seeking market participants’ feedback on its proposed approach to rating Chinese RMBS transactions. Moody's proposed rating approach uses a residential mortgage collateral analysis model (Moody's Individual Loan Analysis, “MILAN”), which is a key element of its loan and portfolio level evaluation. A full explanation of the MILAN methodology may be found here.

Moody’s invites market participants to provide feedback by January 15th 2016, by submitting their comments on the Request for Comment page on


According to Moody’s 2016 CMBS Outlook, the credit profile of conduit/fusion commercial mortgage-backed securities will decline to match levels from mid-2006 to early 2007. Moody’s says that while leverage in conduit/fusion CMBS has topped pre-crisis peak levels, debt service coverage has remained high due to low interest rates, providing good term default risk protection. “With commercial property prices exceeding pre-crisis peaks on an inflation-adjusted basis and most mortgage debt still sized as a percentage of current market value, we are entering the late stages of the current credit cycle,” said Moody’s Director of Commercial Real Estate Research, Tad Philipp. Additionally, according to Moody’s the credit quality of outstanding CMBS will remain stable in 2016.


Last week, Representatives Gwen S. Moore (D-WI) and Steve Stivers (R-OH) wrote to Federal Housing Finance Agency (“FHFA”) Director Mel Watt to voice support for the use of credit-risk sharing transactions to spur the return of private label securitization in the RMBS market. In response to the publication of an Overview of Fannie Mae and Freddie Mac (“GSEs”) Credit Risk Transfer Transaction (“CRT Report”), the lawmakers stated their concern for imbalance between “front-end” and “back-end” risk sharing. 

The CRT Report found that almost all risk sharing in GSE transactions is “back-end,” which occurs after the GSEs purchase a loan or guarantee a mortgage pool and subsequently assume the related risk. The lawmakers expressed a desire to see increased “front-end” risk sharing, which occurs where a seller or lender retains a portion of the related credit risk or obtains mortgage insurance to provide default loss protection. Specifically, the letter inquires as to further FHFA plans to expand “front-end” risk sharing to encourage borrower and lender participation and benefits, ensure the durability of credit risk sharing capacity, and contribute to broader housing reform consideration. The Representatives urged the FHFA to continue working on credit-risk sharing efforts “particularly if, as [they] believe, front-end credit risk sharing offers the prospect of being more affordable for borrowers, providing more protection to taxpayers, and remaining consistent with the other goals of the conservatorship and federal housing policy generally.”


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, Advocacy

Dan Goodwin Director, Mortgage Policy

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

Sarah Clarke Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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