February 3, 2016 Newsletter
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February 3, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


On January 28th, Federal Reserve Board Chair Janet Yellen responded for the record to a question she was asked about H.R. 4166, the Expanding Proven Financing for American Employers Act (“Act”) at a November 4, 2015 hearing before the House Financial Services Committee. H.R. 4166, co-sponsored by Representatives Andy Barr (R-KY) and David Scott (D-GA), creates an SFIG-supported 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.

Specifically, Chair Yellen was asked whether she “would consider such a [QCLO] concept as you examine liquidity in the market, and is the Federal Reserve planning to promulgate any rules or regulations that would include the Qualified CLO concept?”

In her response, Chair Yellen stated that while the Board will not promulgate rules on the QCLO concept, “The [Federal Reserve] Board recognizes that certain structural features of Qualified CLOs may contribute in some degree to aligning the interests of CLO managers with investors with respect to the quality of securitized loans.”

SFIG will continue to work with policymakers to create a workable risk retention regime for CLOs.

To view SFIG’s support letter for H.R. 4166, please click here

To learn more about SFIG’s advocacy efforts on H.R. 4166, please contact Michael.Flood@sfindustry.org.


SFIG is thrilled to announce that, as of today, we have received WiS sponsorship commitments from organizations and individuals totaling more than $100,000! The financial support of the industry highlights the importance of this initiative, and we are very grateful for the generosity of our sponsors. 

WiS is eager to grow even more with the backing of our industry members, and sponsorship remains open. We look forward to continuing to provide quality events and programming to industry women at ABS Vegas 2016 and beyond, and each of our sponsors enhances our ability to do so.

If you are interested in sponsoring WiS and taking advantage of the various benefits available at ABS Vegas 2016 please submit your sponsorship form by Friday, February 5th. WiS offers several tiers for corporate institutions and individuals to determine how they can best contribute. A full review of the benefits available at each level of initiative sponsorship is available here.

SFIG currently has open positions for:

  • Advocacy Manager: will be an integral member of SFIG staff, being second-in-command of the association’s Advocacy department. The successful candidate will design and execute advocacy strategies for SFIG’s policy priorities and support the association’s advocacy efforts through development and growth of its political action committee. Additional information on the position, as well as a link to the application, is available here.

  • Data/Policy Analyst: will help support group-wide strategy efforts and initiatives as they relate to the association’s database and various policy requirements. The Analyst will also support SFIG’s advocacy efforts through development of a political action committee database. 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:

Analyst, Financial Institutions Kroll Bond Rating Agency 02-03-2016
Associate Director, Structured Finance - Toronto Standard & Poor's 01-29-2016
Attorney- Project Finance/Corporates Kroll Bond Rating Agency 01-28-2016

Analyst – CMBS Analytics

Kroll Bond Rating Agency 01-28-2016

Structured Finance Analyst

Assured Guaranty 01-19-2016

Associate Director/Director, Asset Backed

Fitch Ratings 01-12-2016

Associate Director/Director, Residential
Mortgage Backed Securities

Fitch Ratings 01-07-2016
Associate Director, ABS Ratings Standard & Poor's 01-07-2016
Analyst Moody’s Investors Services 12-15-2015
Associate Analyst 1 Moody’s Investors Services 12-15-2015

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

For questions about positions at SFIG, please contact Jobs@sfindustry.org. For questions about the website jobs portal, please contact Website@sfindustry.org.

  • THURSDAY, February 4, 2016
    10:00 a.m. – 11:00 a.m. (EST)
  • THURSDAY, February 11, 2016
    10:00 a.m. – 11:00 a.m. (EST)

MONDAY, February 8, 2016
2:00 p.m. - 3:00 p.m. (EST)


MONDAY, February 8, 2016
2:00 p.m. - 3:00 p.m. (EST)


TUESDAY, February 9, 2016
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.


SUNDAY, February 28, 2016 
3:00 p.m. - 5:00 p.m. PT
The Aria Resort & Casino
Las Vegas, NV


TUESDAY, May 31, 2016 – WEDNESDAY, June 1, 2016
Hyatt Regency Toronto
Toronto, Ontario
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 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 is currently working on establishing and documenting recommended market best practices, with the first call of this initiative taking place next week. The committee previously commented on the Treasury Department's Request for Input on Online Marketplace Lending on September 30th.

Members interested in participating should contact Alyssa.Acevedo@sfindustry.org.

SFIG’s Student Loan Committee recently responded to Fitch’s proposed amendments to FFELP student loan ABS rating methodology. The committee also submitted a response to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans this past October.

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 Amanda.Bateman@sfindustry.org.

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.

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

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 Amanda.Bateman@sfindustry.org 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 Alyssa.Acevedo@sfindustry.org to participate on the Task Force.

The Risk Retention Industry Guide Working Group recently 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 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 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 this past June. SFIG submitted a supplemental comment letter covering credit card and equipment floorplan asset classes on January 12, 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 is currently working on a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The committee is also 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 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 is currently working on 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.

To join the HQS Task Force, please contact Alyssa.Acevedo@sfindustry.org.


Last Wednesday, January 27th, the U.S. Treasury Department’s Office of Financial Research (“OFR”) released its annual report to Congress.

One of the OFR’s key findings related to clearinghouse use for derivatives trades: “…clearing derivatives trades through central counterparties (“CCPs”) has significant benefits in reducing the risks to counterparties of default — as long as the CCP has the resources to meet payment obligations in the event of member default. But a CCP can also be a single point of vulnerability for failure and creates the potential for propagation of risks.”

According to a recent Bloomberg article, regulators and other industry firms have also suggested that there could be too much risk concentrated at clearinghouses.

The OFR also found that rapid, sharp declines in market liquidity “have amplified market shocks” and pose a threat to financial stability. Bloomberg states that regulators are studying the ways in which they can prevent this to help the U.S. Treasury market operate more smoothly.


In 2014, the European Central Bank (“ECB”) “launched a program to buy up asset-backed securities” in an attempt to encourage issuance of European ABS, according to a report in The Wall Street Journal. This program was “part of measures aimed at injecting around €1 trillion ($1.08 trillion) into the eurozone’s financial system.” The program did not result in more issuance however, “in 2015, sales of European ABS were roughly flat and the cost of issuing securitized debt in southern Europe actually increased”. While the U.S. ABS market is expanding, the “overall size of the European ABS market was on track to decline for the seventh straight year in 2015.”

According to the article, “some analysts and investors have criticized the ECB’s approach and the glacial pace” of the ABS purchases. The program “has been modest, with only €16 billion of ABS bought as of January 22 [2016], or around 7% of the market.” By contrast, the ECB’s “government and quasi-sovereign bond-buying program grew to €530 billion after being launched in March 2015.” Other criticisms of the program is that the ECB is “buying too many securities in safer, Northern European countries, rather than focusing on lowering the funding costs in former trouble spots of Southern Europe, where it is needed most.”

The article does cite one clear benefit of the program, according to Richard Hopkin, Head of Fixed Income and a managing director in the Securitization Division at the Association for Financial Markets in Europe, which is that it has been “very helpful in de-stigmatizing the market.”


On Thursday, January 28th, the Department of Housing and Urban Development (“HUD”) announced it would reduce the multifamily insurance premiums (“MIPs”) in an effort to encourage the renovation of affordable housing units and promote energy-efficient upgrades. Effective April 1, 2016, the Federal Housing Administration (“FHA”) is lowering annual MIPs for “Broadly Affordable” housing to 25 basis points, a reduction of 20 to 25 basis points from current rates. FHA is also lowering its premium on mixed-income multifamily properties by 10 to 35 basis points, to 35 basis points.

Additionally, FHA is lowering annual rates for energy efficient multifamily properties to 25 basis points. This reduction of 20 to 45 basis points applies to properties committed to industry-recognized green building standards as well as to energy performance in the top 25 percent of multifamily buildings nationwide. Qualification for the top 25 percent will be determined using EPA’s Portfolio manager 1-100 score.

According to HUD Secretary Julián Castro, “Families across the country are struggling through an affordable housing crisis. By reducing our rates, this Administration is taking a significant step to encourage the preservation and development of affordable and energy efficient housing in communities large and small. This way, hard-working families won’t have to make the false choice between quality or affordable housing.”


According to a recent Fitch Ratings report, RMBS securitization in China is expected to become more popular in the next few years as more banks use RMBS for capital-relief purposes and funding diversification.

As Fitch explains in their press release, six Chinese banks have obtained approval from the People’s Bank of China for RMBS shelf registration totaling ¥215 billion ($32.7 billion).

Fitch received many queries from international investors about this growing sector and addressed the most frequently asked questions in its report, “China Residential Mortgage Securitisations - Frequently Asked Questions.”


The Federal Deposit Insurance Corporation (“FDIC”) recently published their quarterly Supervisory Insights, which included an in-depth section on Marketplace Lending (“MPL”). This write-up gave a broad overview of MPL in general, the importance of effective risk identification (including third-party, compliance, transaction, servicing and liquidity risk), and a supervisory perspective.

The FDIC explained that this discussion was “intended to heighten bankers’ and examiners’ understanding of marketplace lending and potential associated risks, including those arising in third-party arrangements.”

The FDIC also highlighted “the importance of a pragmatic business strategy that considers the degree of risk together with the potential revenue stream, and emphasizes the importance of banks exercising the same due diligence they practice whenever they extend credit to a borrower.”

If you would like to join SFIG’s Marketplace Lending Committee, please contact Alyssa.Acevedo@sfindustry.org.

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

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Senior Policy Analyst

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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