July 24, 2013 Newsletter
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Structured Finance Industry Group


Issue Spotlight

Recent Developments



GSE reform has recently heated up, with the Corker-Warner Bill pending in the U.S. Senate, and the Republicans in the U.S. House of Representatives moving forward with their own piece of GSE reform legislation, the PATH Act.

On the private label RMBS front, press reports on July 24, 2013 indicate that regulators may be re-thinking, and liberalizing, the risk-retention provisions applicable to such securitizations. Many other issues remain, including a number of issues relating to the ability-to-repay/qualified mortgage rule.

SFIG leadership believes that in this environment it is crucial for SFIG to develop a comprehensive approach to these issues. The leadership believes that SFIG has the opportunity to provide a consistent framework in which policy makers, legislators and regulators may consider the interactions between the various components to the mortgage market.

A meeting, described below, was held in New York City on July 24, 2013 to discuss these initiatives.

Among the aspects of SFIG’s approach to the mortgage market’s issues is its partnership with the Mortgage Bankers Association (MBA). The benefits of this partnership are illustrated by the SFIG-MISMO working group described below. Another aspect is the outreach effort evidenced by the holding of the roundtables, also described below.

If you are interested in working with SFIG’s Residential Mortgage Committee on these initiatives, please contact SFIG at Richard.Johns@sfindustry.org.

Overall Mortgage Markets Planning Meeting Held on July 24, 2013
A group of SFIG members representing a broad range of membership from mortgage originators, servicers, analytics firms, law firms, accounting firms, rating agencies and investors met on July 24, 2013 to formulate an SFIG approach to RMBS. The discussion focused on how SFIG can represent the value of securitization to consumers and the economy. The group discussed three components to the plan:

  1. The development of a white paper that describes the purpose and process of securitization with emphasis on the roles of the various parties and the allocation of risks and responsibilities.
  2. A seminar for policy makers in Washington, DC to help communicate these ideas.
  3. Development of a set of principles that will guide SFIG in commenting on GSE reform proposals such as the Corker-Warner Bill and the PATH Act.

The group is in the process of developing a plan to implement these components and involve the broader membership in this effort.

SFIG Meets With Mortgage Bankers Association on Residential Mortgage Loan Level Disclosure
On July 23, 2013, representatives of SFIG’s Residential Mortgage Committee’s Loan Level Disclosure Subcommittee met with representatives from the Mortgage Bankers Association’s subsidiary, the Mortgage Industry Standards Maintenance Organization (MISMO) regarding loan level disclosure for residential mortgage loans.

Items discussed at the meeting included:

  • Objectives for the joint SFIG/MISMO Loan Level Disclosure working group;
  • Expansion of MISMO data points to address considerations in private-label residential mortgage-backed securities issuance; and
  • Work done to date, future meetings and target completion dates of tasks.

MISMO was created to promote and support the common business interests of the commercial and residential mortgage markets. According to its mission statement, its objective is to benefit industry participants and consumers of mortgage and investment products and services by:

  • Fostering an open process to develop, promote, and maintain voluntary electronic commerce procedures and standards for the mortgage industry, and
  • Enabling mortgage lenders, investors, servicers, vendors, borrowers, and other parties to exchange real estate finance-related information and eMortgages more securely, effectively and economically.

MISMO has more than 150 subscriber organizations, including mortgage bankers, lenders, servicers, vendors and service providers. MISMO has working agreements with other major data standards development organizations and has developed a repository of industry data elements stored in a common data dictionary used to create all MISMO transactions. MISMO supports free and open access to the final releases of its standards.

If you are interested in participating in the Loan Level Disclosure Subcommittee, please contact SFIG at Richard.Johns@sfindustry.org.

SFIG Planning Roundtables on Private-Label RMBS
In early August, SFIG’s Residential Mortgage Subcommittee on Representations & Warranties and Repurchase Governance will begin planning the first of a series of roundtables on key topics impacting the return of the private label residential mortgage-backed securities (RMBS) market. Anticipated topics include ability-to-pay/qualified mortgage, issuer and investor alignment, independent review mechanics and different representation and warranty standards in the re-emerging RMBS market.

SFIG members interested in joining the subcommittee and/or working on and participating in the roundtables should contact Eric Kaplan at Eric.Kaplan@shellpointllc.com or SFIG at Richard.Johns@sfindustry.org as soon as possible.



SFIG has formed a Task Force to discuss possible advocacy initiatives regarding changes to money market fund regulations proposed by the Securities and Exchange Commission (SEC).

An organizational call of the Task Force will take place at 3:00 pm Eastern time on July 29, 2013.

Click here for the SEC’s money market fund reform proposal.

SFIG members interested in joining this Task Force should contact SFIG at Richard.Johns@sfindustry.org.



Prompted in part by a new and more conservative capital treatment under BASEL III, a number of banks have recently sold hundreds of billions of dollars in notional amount of residential mortgage servicing rights (MSRs) to non-bank servicers. Some industry observers predict that, over the next five years, $4 trillion in MSRs will be sold to non-bank servicers.

Although the Consumer Financial Protection Bureau (CFPB) released new servicing regulations in January of 2013, to take effect in January of 2014, issues relating to servicing transfers generally were not addressed. In a discussion paper released in September 2011, the Federal Housing Finance Agency (FHFA) did address the related topic of servicing compensation but has yet to take meaningful action regarding servicing compensation or servicing transfers.

Servicing transfers sometimes expose differences in servicing practices and reporting, particularly with respect to loans which have been modified with forbearances. These differences can lead to large charge-offs reported in the months following a servicing transfer, which can surprise investors and potentially affect cashflows.

Another consequence of these servicing transfers has been renewed interest in financing and securitization transactions involving MSRs, particularly by real estate investment trusts (REITs).

The Effect of Basel III’s Capital Requirements

A number of industry observers believe that the recent increase in servicing transfers has been prompted by the change in bank capital requirements for MSRs required by BASEL III. Pursuant to the new requirements, the value of MSRs cannot exceed 10% of the common equity component of a bank’s tier one capital. In addition to the extent that the aggregate value of MSRs, deferred tax assets and significant investments in the form of common stocks in the capital of unconsolidated financial institutions, exceeds 15% of the common equity component of a bank’s tier one capital, that excess must be deducted from that component of tier one capital. Under BASEL III, any MSRs not deducted from capital would be risk-weighted at 250%; the current risk-weighting for MSRs is 100%.

As the Mortgage Bankers Association (MBA) put it on July 2, 2013 (the date on which the Board of Governors of the Federal Reserve System approved the U.S. version of the BASEL III rules), “[m]ortgage servicing assets were not given favorable treatment in the Final Rule.”

Due to this unfavorable capital treatment, the MBA predicts that there may be an arbitrage opportunity created in the market which favors non-bank servicers.

According to the industry trade publication Inside Mortgage Finance, the four largest mortgage originators — Wells Fargo & Co., Bank of America Corp., JPMorgan Chase & Co., and Citigroup Inc. — had 50.3% of the servicing market at the end of the first quarter of 2013. That figure is down from 54.2% a year earlier. Servicing rights at Bank of America, JPMorgan and Citigroup fell $545 billion, or 14%, in the past 12 months.

Among the largest purchasers of the MSRs being sold by the banks is Nationstar Mortgage Holdings Inc., 77% of which is owned by funds controlled by Fortress Investment Group. Nationstar added $36.3 billion to its servicing portfolio during the first quarter of 2013 from a year earlier, and had a servicing portfolio of $103.3 billion on March 31, 2013. Between March 31, 2013 and the end of 2013, Nationstar expects to add an additional $437 billion in new servicing rights, representing acquisitions from Aurora Bank F.S.B., a unit of Lehman Brothers Holdings, Inc. and $374 billion from Residential Capital LLC, a division of Ally Financial Inc.

Ocwen Financial Corp is another major acquirer of mortgage servicing rights. Ocwen, with $95 billion in servicing rights as of March 31, 2013, acquired $30.3 billion of servicing rights in the second quarter from JPMorgan and Saxon Mortgage Services Inc., a former unit of Morgan Stanley, and is expected to add $10.7 billion of servicing rights acquired from Bank of America. In 2013, Ocwen purchased Litton Loan Servicing LP’s $51.2 billion mortgage servicing portfolio from Goldman Sachs Group Inc.

Servicing Transfers May Expose Differences in Reporting Requirements

Private label RMBS investors have become aware of a concern with mortgage servicing transfers that stems from differing reporting practices between the former and the acquiring servicer.

Specifically, the reporting issue arises when loan modifications result in principal forbearance. The forbearance of principal resulting from a modification essentially becomes a balloon payment at the end of the loan’s term. Under the U.S. Department of the Treasury’s (Treasury) guidance for forbearances under the Home Affordable Modification Program (HAMP), those balloon payments should be treated as a loss on the loan. This practice, however, is not required outside of the HAMP program, and servicing practices and reporting differ among servicers.

As a result, the successor servicer following a servicing transfer has some leeway in reporting. If the new servicer’s practice is to recognize a loss on the forborne principal, that may lead to substantial, and unexpected losses being recognized by the securitization trust holding the related loans.

According to a representative of Fitch Ratings recently quoted in the National Mortgage News, the differences in reporting practices “is a big concern for RMBS investors, specifically for subordinate bondholders which are sensitive to the timing of losses. Cash flow volatility due to unexpected servicing changes like this makes it difficult to appropriately price the bonds. That representative added, however, that Fitch thinks that the likelihood of further large revisions “is limited.”

Other Regulatory Responses

Another issue related to servicing transfers is servicing compensation, since any major change in the way servicers are compensated would be expected to impact the market for MSRs. The FHFA has not taken any action with respect to servicing transfers, although in September 2011 it did release for public comment its “Alternative Mortgage Servicing Compensation Discussion Paper” (Discussion Paper) relating to servicer compensation.

While a number of comments were submitted on the Discussion Paper, the FHFA has not revisited the issue of servicer compensation. In a speech delivered on December 6, 2012 to the Securities Industry and Financial Markets Association on “Building a Mortgage Infrastructure for the Future,” FHFA Acting Director Edward DeMarco referenced the Discussion Paper and stated that “we have already completed a substantial amount of groundwork on this [servicing compensation] subject. It remains for me an important part of the work ahead.”

On January 17, 2013, the CFPB issued final rules (CFPB Servicing Rules) on mortgage servicing under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z). The CFPB Servicing Rules take effect on January 10, 2014.

The CFPB Servicing Rules do not address servicing transfers or servicing compensation with any level of detail. The CFPB Servicing Rules do address a given servicer’s obligation with respect to correcting errors alleged by borrowers, forced-placed insurance, continuity of contract between borrowers and servicing personnel, periodic statements to borrowers and various other items.

On February 11, 2013, the CFPB issued its Bulletin 2013-01, “Mortgage Servicing Transfers” (CFPB Bulletin) which did specifically address servicing transfers, but only in rather general terms. In the CFPB Bulletin, the CFPB cautioned servicers that its examiners would be “carefully reviewing servicers’ compliance with federal laws applicable to servicing,” including the Real Estate Settlement Procedures Act, the Fair Credit Reporting Act, the Fair Debt Collections Act and prohibitions against unfair, deceptive or abusive acts or practices.

The CFPB also stated that its examiners will assess “the policies, procedures, systems and controls that servicers have established to address the risks to consumers in connection with servicing transfers. Moreover, examiners are assessing whether mortgage servicers are adequately staffed and are ensuring that their employees are trained to handle consumer communications in the context of servicing transfers.”

Furthermore, the CFPB added that “in appropriate cases,” the CFPB will require servicers “engaged in significant servicing transfers to prepare and submit written plans to the CFPB detailing how they will manage the associated consumer risks.”The CFPB acknowledged that servicers do not need approval from the CFPB before consummating a servicing transfer.

On June 4, 2013, Federal Housing Administration Commissioner Carol Galante testified before the U.S. Senate’s Committee on Appropriations Subcommittee on Transportation Housing and Urban Development, and Related Agencies (Galante Testimony). In her testimony, Commissioner Galante asked for legislation that would allow the Federal Housing Administration (FHA) to transfer the servicing on FHA-insured mortgage loans whenever a Servicer gets rated at or below the FHA’s servicer tier ranking score of III, or whenever the FHA deems the action necessary to protect the interest of the Mutual Mortgage Insurance Fund that backstops the FHA insurance.

Several industry experts, while noting that Commissioner Galante’s request on behalf of the FHA was not new, suggested that giving the FHA the power to force a servicing transfer could reduce the value of the right to service FHA loans, affecting the pricing if not the market for voluntary servicing transfers of FHA loans.

Financing Transaction in MSRs

As banks transfer MSRs to non-bank servicers that are unable to finance these assets through a deposit base, financing transactions involving MSRs may become more common, especially involving “excess servicing rights.”

The term “excess servicing rights” (ESRs) refers to the excess of the specified servicing fee for a loan over the actual costs of servicing that loan. For GSE loans, the minimum servicing fee is 25 basis points. For Ginnie Mae Loans, the minimum fee is 44 basis points (19 for loans in the “Ginnie II” program). Non-agency loans generally have servicing fees in the 25-50 basis point range. Most industry experts believe that a substantial portion of these servicing fees exceed the actual cost of servicing, and ESRs are created as a result.

On August 24, 2012, the Internal Revenue Service (IRS) released a private letter ruling of significance to the financing of ESRs. The private letter ruling, denoted as number 201234006 (PLR), answered several questions posed by a mortgage REIT in connection with its proposed acquisition of ESRs.

In the PLR, the IRS ruled that (i) ESRs acquired by the REIT would be considered an interest in mortgages on real property and thus a real estate asset qualifying for the 75% asset test applicable to REITs, and (ii) interest income received by the REIT from ESRs would be deemed to be derived from interest on obligations secured by mortgages on real property. That interest income would qualify for the 75% income test applicable to REITs.

The PLR allows parties to evaluate the use of a REIT as a vehicle to finance a non-bank servicer’s acquisition of MSRs, by having a REIT purchase the ESRs from the servicer.

One major investment bank has stated that it sees a potential for a $2-3 billion market in ESR transactions during 2013 and into 2014. Industry observers have cited several mortgage REITs as likely participants in these transactions, including PennyMac Mortgage Investment Trust, Newcastle Investment, Two Harbors and Invesco Mortgage.

In addition to being a potentially alternative investment for REITs, ESRs can also serve as the basis for a securitization. According to press reports, Ally Financial consummated a $1.2 billion securitization of ESRs in March of 2011. Industry experts expect more such transactions, in addition to the REIT-based transactions, as non-bank servicers continue to seek financing for their ongoing acquisitions of MSRs.

If you are interested in participating in SFIG’s Residential Mortgage Committee, in SFIG’s Investor Committee, or in SFIG’s Servicer Committee, please contact SFIG at Richard.Johns@sfindustry.org.

Click here for the FHFA’s Discussion Paper. Click here for the CFPB Servicing Rules. Click here for the CFPB Bulletin. Click here for the Galante Testimony. Click here for the PLR.




On July 23, 2013, the U.S. House of Representative’s Committee on Financial Services held a mark-up on the “Protecting American Taxpayers and Homeowners Act of 2013” (PATH Act). The PATH Act is a piece of legislation that, if enacted, would eliminate Fannie Mae and Freddie Mac and scale back the federal government’s involvement in guaranteeing mortgage-backed securities. The Act would preserve the Federal Housing Administration and Ginnie Mae.

The lead sponsor of the PATH Act is Rep. Jeb Hensarling (R-TX), the Chairman of the House Financial Services Committee. The PATH Act is the House Republicans’ answer to the “Housing Finance Reform and Taxpayer Protection Act of 2013” (Corker-Warner Bill), which is pending in the U.S. Senate. The Senate’s bill has been introduced on a bi-partisan basis by lead sponsors Senator Bob Corker (R-TX) and Mark Warner (D-VA).

According to press reports, Rep. Hensarling is anticipating a full House vote on the PATH Act before the August Congressional recess.

According to an item appearing on July 20, 2013 in the Washington publication The Hill, U.S. Treasury Secretary Jacob Lew has stated that the Obama Administration favors the Senate’s Corker-Warner Bill.

The Hill item quotes Secretary Lew as saying “I think that if you contrast what the conversation in the Senate is to the conversation in the House, it’s kind of interesting that one is a bipartisan conversation and the other is not. This is going to require a bipartisan solution, and we look forward to being part of it.”

Click here for the PATH Act. Click here for the Corker-Warner Bill.



The U.S. Department of Labor has amended, in Prohibited Transaction Exemption 2013-8, the definition of “rating agency” in Prohibited Transaction Exemption 2007-05, the so-called “Underwriter Exemption” under the Employee Retirement Income Security Act of 1974 (ERISA). As a result of the amendment, each of Kroll Bond Rating Agency and Morningstar Credit Ratings LLC will be considered as a “rating agency” under the Underwriter Exemption.

A “rating agency” under the revised Underwriter Exemption means a credit rating agency that:

  1. is currently recognized by the U.S. Securities and Exchange Commission (SEC) as a nationally recognized statistical rating organization (NRSRO);
  2. has indicated on its most recently filed SEC Form NRSRO that it rates “issuers of asset-backed securities;”
  3. has had, within a period not exceeding 12 months prior to the initial issuance of the securities, at least three “qualified ratings engagements,” which are defined as engagements requested by an issuer or underwriter of securities in connection with an initial offering of those securities, for which the credit rating agency was compensated, which is made public to investors generally, and which involves the offering of securities of the type that would be granted relief by the Underwriter Exemption.

Click here for the amended Underwriter Exemption.



In a July 22, 2013 posting to its “Treasury Notes” blog, the U.S. Department of the Treasury (Treasury) posted an item relating to the Home Affordable Modification Program (HAMP) entitled “Understanding HAMP Re-Default Rates.”

The blog posting describes some of the changes Treasury has made to HAMP in an attempt to reduce re-defaults (instances in which homeowners who receive assistance through HAMP later default on their modified payments).

Treasury noted that since it began publishing delinquency and re-default data under HAMP in 2010, the performance of HAMP modifications has improved, and “is strongly correlated with the amount of the payment reduction.”

According to the blog posting:

  • For modifications in effect for one year, 20.5% of these modifications started in the third quarter of 2009 have re-defaulted, compared to only 10.7% for these modifications started in the first quarter of 2012.
  • For modifications in effect for two years, only 16.5% of these modifications with a monthly payment reduction greater than 50% have re-defaulted, compared to a disqualification rate of 42.6% where the payment has been cut by 20% or less.
  • Studies by the Office of the Comptroller of the Currency have found that homeowners in HAMP “consistently exhibit lower delinquency and re-default rates than those in private industry modifications.”

Click here for the Treasury Notes blog posting.



Rep. Mel Watt (D-NC), President Obama’s nominee to serve as Director of the Federal Housing Finance Agency (FHFA), was approved on a party-line vote in the Senate Banking Committee on July 18, 2013. His nomination now comes before the full U.S. Senate.

Rep. Watt’s U.S. Senate vote will come on the heels of the Senate’s reaching an accord on the use of Senate Rule XXII — the so-called “filibuster” — to move forward with several of the President’s other nominees, including Richard Cordray as Director of the Consumer Finance Protection Bureau.

According to a press report in the Washington publication The Hill, Rep. Watt will be “one of the first contentious nominees to hit the [Senate] floor under the new, more agreeable Senate, and will test the boundaries of the deal hammered out between Senate Majority Leader Henry Reid (D-NV) and Senator John McCain (R-AZ).”

Republicans claim that Rep. Watt lacks “the technical expertise and political independence for the job,” according to The Hill report.

Among the Republican Senators opposing Rep. Watt’s nomination are Mike Crapo (R-ID), the Ranking Member of the Senate Banking Committee, and Bob Corker (R-TN). Senator Corker is one of the two lead sponsors, with Senator Mark Warner (D-VA), of the “Housing Finance Reform and Taxpayer Protection Act of 2013,” a piece of legislation that, if adopted, would eliminate the FHFA.

Click here for the report on Rep. Watt’s nomination from The Hill.



On July 18, 2013, the Federal Reserve Bank of New York (New York Fed) published the latest edition of its policy-oriented journal Economic Policy Review. This edition contained an article, “Shadow Banking,” co-authored by Zoltan Pozsar, a senior advisor at the U.S. Department of the Treasury’s Office of Financial Research, Tobias Adrian, a vice president at the New York Fed, Adam Ashcraft, a senior vice president at the New York Fed, and Hayley Boesky, a vice chairman at Bank of America Merrill Lynch.

The authors use the term “shadow banking” to describe a system in which credit is intermediated “through a wide range of securitization and secured funding techniques, including asset-backed commercial paper (CP), asset-backed securities (ABS), collateralized debt obligation (CDOs) and repurchase agreements (repos).”

“Shadow banks” are financial intermediaries that conduct maturity, credit and liquidity transformation. According to the article, these intermediaries contributed to asset price appreciation and the expansion of credit prior to the financial crisis, and that their vulnerabilities were exposed during the crisis, ultimately compelling the Board of Governors of the Federal Reserve System (Federal Reserve) and other government agencies to provide emergency support.

Using the Federal Reserve’s “Flow of Funds” data, the authors estimate that the shadow banking system’s liabilities were $22 trillion in 2007. The “traditional” banking system’s deposit-funded liabilities were estimated to be $14 trillion in 2007. However, the size of the shadow banking system has contracted substantially since 2007, while the total liabilities of the traditional banking system have increased since that time.

The authors contend that despite efforts to address the excesses of credit bubbles, the shadow banking system will likely continue to play a significant role in the financial system for the foreseeable future. Furthermore, increased capital and liquidity requirements for traditional banking system are “likely to increase the returns to shadow banking activity,” partially because reform efforts have done “little to address the lending of large institutional cash pools to form outside the banking system.”

If you are interested in joining SFIG’s Shadow Banking Issue Task Force, please contact SFIG at Richard.Johns@sfindustry.org.

Click here for the Shadow Banking article.



On July 15, 2013, over fifty community groups and unions sent a letter (Community Group Letter) to Congress urging its members “to watch for and reject measures that would mandate discrimination by federal agencies against mortgage loans made in communities that implement local principal reduction programs. The Community Group Letter went on to urge members of Congress to resist efforts by the Federal Housing Finance Agency and the U.S. Department of Housing and Urban Development to adopt policies that would restrict the use of eminent domain in response to “underwater” mortgage loans (mortgage loans for which the outstanding principal balance of the mortgage note exceeds the current fair market value of the related property).

The Community Group Letter specifically criticizes the advocacy efforts of the Securities Industry and Financial Markets Association (SIFMA) against the use of the eminent domain doctrine with respect to underwater mortgage loans. SIFMA has submitted its own letter (SIFMA Letter) to Congress opposing this proposed use of eminent domain.

SFIG is largely in agreement with the points raised in the SIFMA Letter. SFIG’s Residential Mortgage Committee is in the process of developing SFIG’s specific position on the eminent domain issue.

Click here for the Community Group Letter. Click here for the SIFMA Letter.

If you are interested in joining SFIG’s Residential Mortgage Committee, please contact SFIG at Richard.Johns@sfindustry.org.



The Consumer Financial Protection Bureau (CFPB) announced on July 15, 2013, the addition of four new senior staff members:

  • Sartaj Alag was appointed Chief Operating Officer of the CFPB. Mr. Alag is returning to the CFPB, where in his previous role he was in charge of starting up and managing the Office of Consumer Response. His experience before that included an executive position at Capital One.
  • Christopher D’Angelo was named as the CFPB’s Chief of Staff. Mr. D’Angelo was elevated from his previous position as Senior Advisor to CFPB Director Richard Cordray. Mr. D’Angelo is an attorney whose previous experience includes a position as Senior Advisor to the Under Secretary for Domestic Finance at the U.S. Department of the Treasury.
  • Nora Dowd Eisenhower was appointed as the new Assistant Director for the Office of Older Americans. Ms. Eisenhower previously served on the National Council on Aging, where she was the Director of the National Center for Benefits Outreach and Enrollment, then Senior Vice President of Economic Security. Ms. Eisenhower is an attorney.
  • Laurie Maggiano was named as the CFPB’s Program Manager for Servicing and Securitization Markets in the Division of Research, Markets and Regulations. Ms. Maggiano’s previous position was at the U.S. Department of the Treasury, where she served as the Director of Policy in the Office of Homeownership Preservation, and was one of the principal architects of the Making Home Affordable program.

Click here for the CFPB announcement regarding the new hires.



ABS Vegas 2014 – January 21-24, Las Vegas, Nevada. Click here for more information.

SFIG is now accepting sponsorship contracts for this conference. If you are interested, please contact SFIG.



SFIG has a number of Committees and Task Forces meeting and working on many topics of interest to the securitization industry. Please visit our website 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 (www.sfindustry.org) to learn about membership opportunities.


Contact us at info@sfindustry.org


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