July 27, 2016 Newsletter
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July 27, 2016

Important Announcement


Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


As many of you are used to receiving SFIG's weekly newsletter every Wednesday evening, we wanted to let you know that we will be adjusting the delivery times over the next few weeks. If you haven't received our newsletter by Wednesday,
rest assured that you will have it in your inbox on Thursday morning.
Thank you so much for your attention.
And, as always, please let us know if you have any questions.

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SFIG will be hosting a series of updates on key initiatives this year at IMN’s 22nd Annual ABS East, taking place September 18-20 at the Fontainebleau in Miami Beach. These special SFIG sessions will take place on Sunday, September 18th from 12:30 p.m. – 4:30 p.m., Track C. Advocacy efforts to be covered include RMBS 3.0, Reg AB II and marketplace lending. Investor closed door roundtable discussions will also be held covering Market Liquidity and the SFIG Investor advocacy agenda. More detailed agenda will be available here.

ABS East has already confirmed over 1,300 investors and issuers, and will feature keynote addresses from Patrick Foulis, Bureau Chief and U.S. Business Editor, New York, The Economist and Steve Eisman, Managing Director, Portfolio Manager, Neuberger Berman and a key character in Michael Lewis's “The Big Short”.

Be sure to reserve your place by Friday, July 29th, for Early Bird savings.

Please stay tuned for more details of SFIG’s Women in Securitization special event on Sunday afternoon, September 18th

If you are interested in sponsorship opportunities, please contact Chris Keeping at ckeeping@imn.org or +1 212-901-0533. 

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Register now to attend 1 of 10 regional roundtable events from August 1st – 5th.

The theme of WiS Week 2016 is “Empowering Women to Succeed” and the topic to be presented at each roundtable is Negotiating for Yourself.

Don’t miss the unique opportunity to discuss this customized video presentation created for women. This active session will provide you with a negotiation approach and concrete tools that you can use in future negotiations on advancement, compensation, or exploring new opportunities.

WiS Week events are taking place in CharlotteChicago, HoustonLos Angeles, New York (multiple locations including Fitch Ratings, DBRS, Katten and Wilmington Trust), Toronto, and Washington D.C..

As the same content will be covered at each roundtable, we ask that you register for only one event.

Due to targeted content and limited capacity, registration is limited to women only.

WiS looks forward to welcoming men to our next event at ABS East on September 18th.

Register for an event here.

For questions, please contact wis@sfindustry.org.

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SFIG & co-host IMN are excited to announce that SFIG Vegas 2017 will take place February 26 - March 1, 2017, at the Aria Resort & Casino in Las Vegas. Following the great success of the 2016 program, which featured over 6,700 registrants and more than 160 sponsors, we look forward to providing the securitization market with the industry's largest gathering again next year.

The conference name is also changing this year to SFIG Vegas, to recognize an agenda that encompasses all areas of the structured finance industry, as well as to provide consistency across all SFIG & IMN hosted conferences.


SFIG members receive special discounted rates off registration and sponsorship:
For sponsorship information, please contact Christopher Keeping
at +1 212.901.0533 or ckeeping@imn.org

View 2017 Sponsorship Opportunities

Speaking at SFIG Vegas 2017:

Agenda and Speaker Nomination Process to be Announced Soon

Reserve your place today!

About SFIG Vegas 2017

The three-and-a-half day program is developed by leaders within the structured finance industry representing the full spectrum of industry participants including investors, issuers, financial intermediaries, regulators, law firms, accounting firms, technology firms, rating agencies, servicers and trustees.

SFIG and IMN will work together to ensure all stakeholders’ interests are fairly and equally represented at the event. Topics to be covered range from the more traditional ABS asset classes including autos, CLOs, credit cards, residential, commercial and agency mortgages, and student loans, to the more esoteric and high growth sectors such as solar, REO to Rental, blockchain, and online lending.

Please click here for membership information.

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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. View additional information and apply here.
  • MBS/CMBS Policy Manager: will contribute to the design of, and help execute group-wide strategy efforts and initiatives in support of SFIG’s advocacy, education, and policy priorities. View additional information and apply here.
  • Manager of Advocacy: will design and execute advocacy strategies for SFIG’s policy priorities and also support SFIG’s advocacy efforts through development and growth of its political action committee. View additional information and apply here.
  • Policy Analyst: will help support policy initiatives and investor relations, through direct member engagement, meeting facilitation, research and analysis. View additional information and apply here.

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:

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.

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

Current members are encouraged to advertise open positions within their company on SFIG's website by filling out the form here.

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TUESDAY, August 2, 2016
11:00 a.m. – 12:00 p.m. (ET)

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THURSDAY, August 4, 2016
10:00 a.m. – 11:00 a.m. (ET)

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MONDAY, August 1, 2016 – FRIDAY, August 5, 2016
Registration for WiS Week roundtables available here.

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

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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 on September 30th.

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 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 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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Last Thursday, July 21st, Senators Sherrod Brown (D-OH) and Jeff Merkley (D-OR) submitted a letter to the heads of the Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Consumer Financial Protection Bureau. The letter calls upon the leaders of these US banking and consumer protection agencies to outline the steps that they are taking to ensure effective oversight and application of the emerging blockchain financial technology. The letter specifically asks the agencies to describe what they have “done to study and understand…blockchain and distributed ledgers…”

The Senators also noted in their letter, "As Congress considers its role in overseeing fintech and its impact on American consumers, we believe it is important that Congress better understand the way federal regulators oversee fintech and their relationships with federally regulated financial institutions.”

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On Friday, two new proposals aimed at modifying language in the Truth in Lending Act (TILA) and Consumer Leasing Act (CLA) were released by federal regulators. Both proposals are being reviewed by the Consumer Financial Protection Bureau, the Federal Reserve, and the Office of the Comptroller of the Currency.

According to a recent article in National Mortgage News, the proposals targeting TILA and the CLA would serve to widen certain reporting exemptions for lenders depending on inflation levels attached to the Consumer Price Index for Urban Wage Earners and Clerical Workers, or CPI-W.

The first proposal – which modifies current regulations in TILA – creates new appraisal thresholds requiring lenders to physically visit homes before determining the home’s value (particularly homes valued above $50,000). The second proposal is concerned with consumers’ “credit and leasing agreements,” which would extend to auto and property loans.

According to the article, “If there is no change from year to year in the CPI-W, the agencies will leave the threshold unchanged. The proposal will formalize the approach that the agencies have taken toward the thresholds since the Dodd-Frank amendments went into effect in 2011.”

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On Friday, July 22nd, the Agricultural Bank of China announced plans to sell 3.06 billion yuan ($464 million) of securities backed by non-performing loans (NPLs). According to a recent report by Reuters, the sale represents part of a broader strategy by Chinese authorities to reduce corporate debt, perceived as a major source of risk for the country’s economy. The securities are backed by 10.7 billion yuan ($1.6 billion) in secured loans, made to 204 borrowers operating in industries such as “wholesale, manufacturing, real estate and transportation.”

The move represents the biggest asset sale yet under the Government’s pilot program, and only the third sale of securities backed by NPLs since 2008. In reference to the program, Elaine Ng, analyst at Moody's Investors Service, has said that "it will be good for ABS market diversity if there are more NPL securitizations from different banks."

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The Office of Financial Research (OFR) has released an assessment of how the Brexit vote has raised the threat level of U.S. financial stability, according to a recent Financial Times article.

“The result of the U.K. referendum surprised financial markets and was a negative shock to investor confidence. It introduces months or years of uncertainty about the rules governing the U.K.’s investment, financing, and trade relations with Europe and the rest of the world,” OFR Director Richard Berner said in a statement.

The OFR has highlighted the dangers posed by the aftermath of Brexit. “Larger shocks to confidence are possible as those deliberations and negotiations play out,” Mr. Berner said. “Because the U.K. economy and especially the U.K. financial system are highly connected with the rest of Europe and the United States, severe adverse outcomes in the U.K. and spillovers to Europe could pose a risk to U.S. financial stability.”

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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
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Washington, DC 20006

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