June 22, 2016 Newsletter
To ensure receipt of this newsletter, please add info@sfindustry.org to your address book. 
Problem viewing this email? Click here for our online version.
June 22, 2016
 
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
SFIG SUBMITS SUPPLEMENTAL COMMENT LETTER TO SEC ON STUDENT LOAN ABS DISCLOSURE

Last Wednesday, June 15th, SFIG submitted a comment letter, drafted by Morgan Lewis, to the U.S. Securities and Exchange Commission (“SEC”) regarding asset-level information for student loans, to address one of the deferred actions within the Regulation AB II final rule. This letter follows our previous comment letter in January 2016 as well as our June 2015 submission to the SEC.

Future discussions across the asset class committees and the Regulation AB II Task Force will focus on the remaining outstanding proposed rules, including requiring issuers to provide the same disclosure for Rule 144A offerings as required for registered offerings. If you would like to participate in these discussions, please contact Alyssa.Acevedo@sfindustry.org.

  Back to top
 
SFIG ANNOUNCES 2016 WiS WEEK SCHEDULE

Following the successful inaugural series of events during WiS Week 2015, SFIG’s Women in Securitization (“WiS”) initiative is proud to announce our next series of regional roundtable events to be held this August in various cities. The discussion topic will be “Empowering Women to Succeed”. WiS Week will provide attendees the opportunity to discuss strategies and solutions for success in the structured finance industry, on topics such as career advancement and advocating for oneself.

We are excited to announce the following WiS Week roundtables:

MONDAY, August 1st

  • 8:30am – 10:30am (PT), hosted by Mayer Brown LLP in Los Angeles, CA
  • 3:00pm – 5:00pm (ET), hosted by Wells Fargo in Charlotte, NC
  • 4:00pm – 6:00pm (ET), hosted by Katten Muchin Rosenman LLP in New York, NY
  • 5:00pm – 7:00pm (CT), hosted by DBRS in Chicago, IL

TUESDAY, August 2nd

  • 8:30am – 10:30am (ET), hosted by Fitch Ratings in New York, NY

WEDNESDAY, August 3rd

  • 11:30am – 1:30pm (ET), hosted by McCarthy Tétrault LLP in Toronto, Canada
  • 12:00pm – 2:00pm (ET), hosted by Wilmington Trust in New York, NY

THURSDAY, August 4th

  • 5:00pm – 7:00pm (ET), hosted by DBRS in New York, NY
  • 6:00pm – 8:00pm (CT), hosted by Ernst & Young in Houston, TX

Registration is forthcoming. As the discussion topics and content will be consistent at each roundtable event, we ask that attendees choose the date that is most convenient.

We would like to thank the above organizations for partnering with WiS by hosting the regional roundtable series.

For questions, please contact wis@sfindustry.org.

  Back to top
 
KEYNOTE SPEAKER OF ABS EAST 2016 ANNOUNCED. REGISTER NOW!

SFIG is proud to be the Lead Association Partner for IMN’s 22nd Annual ABS East Conference, taking place at the Fontainebleau in Miami Beach September 18th – 20th. The 2016 program will feature Steven Eisman, subject of Michael Lewis's The Big Short, Managing Director, Portfolio Manager, Neuberger Berman, as the keynote speaker. [View Full Bio]

Nearly 750 issuers/investors have already confirmed their attendance. Be sure to reserve your place by this Friday, June 24th, to take advantage of Super Early Bird savings, and join industry professionals for one of the year’s most important structured finance conferences.

SFIG will also host a special Women in Securitization event on Sunday, September 18th, from 3:00 p.m. – 5:00 p.m. We look forward to seeing you there!

You can view the preliminary agenda here. For more details on sponsorship, please contact Chris Keeping at ckeeping@imn.org or 1 (212) 901-0533.

  Back to top
 
REMINDER: SFIG RMBS 3.0 TRID COMPLIANCE REVIEW SCOPE© AVAILABLE FOR PURCHASE

SFIG published its RMBS 3.0 TRID Compliance Review Scope© documentation on June 15th. The document was created with an aim to facilitate a uniform testing standard as a result of a consistent Truth-In-Lending Act liability interpretation according to our understanding of prevailing legal precedent and informal written guidance and webinars offered by the CFPB, as it applies to the Know Before You Owe / Truth In Lending Act (“TILA) – Real Estate Settlement Procedures Act (“RESPA”) Integrated Disclosure (“TRID”) Rule (78 FR 79730, as amended) across TPR firms.

If you are not an SFIG member and would like to purchase a PDF copy of the document, please click here. Its purchase entitles you to free periodic updates to the grid.

For questions please contact Daniel.Goodwin@sfindustry.org or Amanda.Bateman@sfindustry.org.

  Back to top
 
INDUSTRY JOBS

SFIG Positions

With SFIG continuing to expand its reach across new conferences and additional policy challenges, we are looking for additional talent.

If you are smart, hard-working, enthusiastic, and want to be part of a growing organization in a fun and supportive environment, please contact us at jobs@sfindustry.org or visit our website at www.sfindustry.org/jobs.

Opportunities exist for a variety of experience sets, ranging from Policy Analyst to Advocacy Manager. We look forward to hearing from you!


Industry Positions

Some of the latest industry positions available include:

JOB TITLE COMPANY POSTING DATE
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.

 Back to top
 
SFIG CALENDAR
MEETINGS
REGULATORY CAPITAL AND LIQUIDITY COMMITTEE CALL

FRIDAY, June 24, 2016
1:00 p.m. – 2:00 p.m. (ET)

 
 
RMBS 3.0 DUE DILIGENCE, DATA AND DISCLOSURE WORKING GROUP CALL

MONDAY, June 27, 2016
2:00 p.m. – 3:00 p.m. (ET)

 
 
RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, June 28, 2016
11:00 a.m. – 12:00 p.m. (ET)

 
 
RMBS 3.0 ROLE OF TRANSACTION PARTIES WORKING GROUP CALL

THURSDAY, June 30, 2016
2:00 p.m. – 3:00 p.m. (ET)

Back to top 
 
EVENTS
SFIG BOARD OF DIRECTORS MEETING

TUESDAY, June 28, 2016
12:00 p.m. – 5:00 p.m. (ET)
Morgan, Lewis and Bockius LLP
New York, NY
Note: Closed Meeting

Back to top
 
WOMEN IN SECURITIZATION (“WiS”) WEEK

MONDAY, August 1, 2016 – FRIDAY, August 5, 2016
Registration forthcoming

Back to top
 
IMN’s ABS EAST 2016 CONFERENCE

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

Back to top
 
ADVOCACY OUTLOOK

If you would like to participate in the work SFIG is undertaking through our committees as highlighted below, please e-mail Committees@sfindustry.org. For specific inquiries on any of SFIG’s advocacy efforts, please contact the staff member listed for the related project.

SFIG’s Marketplace Lending Committee was established in August 2015, as an SFIG participant committee and is open to all SFIG members who have a legitimate interest in marketplace lending. The committee was formed with two primary intentions: 1) to work with members involved in marketplace lending to educate the industry as a whole, with a particular focus on the securitization of assets generated through that lending channel; and 2) to determine appropriate securitization-specific policy and engage in related advocacy, leveraging SFIG’s prominence and experience across all asset classes to support the continued responsible growth of securitization in marketplace lending.

The committee recently launched its “Best Practices” initiative to establish industry consensus and provide recommendations around one or multiple accepted approaches. The five established Best Practices work streams are 1) Data & Reporting 2) Representations & Warranties 3) Regulatory 4) Operational Considerations and 5) Enforcement.

The committee previously commented on the Treasury Department's Request for Input on Online Marketplace Lending on September 30th.

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 recently completed their White Paper, A Comprehensive Guide to U.S. Securitization, 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 a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations and will be addressing industry concerns related to the Federal Reserve Board’s Final Rule on the Liquidity Coverage Ratio (“LCR”). SFIG recently testified before Congress, 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 recently testified before Congress, focusing on global regulatory issues, including HQS, that affect lending across all asset classes.

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

Back to top
 
INDUSTRY NEWS HIGHLIGHTS
BoE TO ENCOURAGE FINTECH AND BLOCKCHAIN INNOVATION

During a recent speech, Mark Carney, Governor of the Bank of England (“BoE”), announced the BoE’s “accelerator” plan to encourage financial technology innovation and build upon the blockchain concept. The BoE will be collaborating with companies that are designing innovative payment systems and cybersecurity, according to a recent article by The Guardian.

Carney explained that the BoE “is devoting considerable resources to ensure whatever develops is sustainable, not ephemeral,” and that it will “change the nature of money, shake the foundations of central banking and deliver nothing less than a democratic revolution for all who use financial services.”

The accelerator plan will work with new technology firms to help harness fintech innovations for central banking and, in turn, allow firms the chance to demonstrate their solutions for real issues facing policymakers, according to Carney. The governor also touched on blockchain technology, stating that, “The great promise of distributed ledgers for central banks is their potential to enhance resilience.”

If you would like to join SFIG’s Blockchain Task Force, please contact Alyssa.Acevedo@sfindustry.org.

Back to top
 
SENATE BANKING COMMITTEE TO HOLD HEARING ON CAPITAL AND LIQUIDITY

On Thursday, June 23rd, the Senate Committee on Banking, Housing and Urban Affairs will hold a hearing entitled “Bank Capital and Liquidity Regulation Part II: Industry Perspectives.” The witnesses scheduled to testify are Ms. Rebeca Romero Rainey, Chairman and Chief Executive Officer, Centinel Bank of Taos (on behalf of the Independent Community Bankers of America); The Honorable Wayne A. Abernathy, Executive Vice President, Financial Institutions Policy and Regulatory Affairs, American Bankers Association; The Honorable Greg Baer, President, The Clearing House Association and Executive Vice President and General Counsel, The Clearing House Payments Company; and Ms. Jennifer Taub, Professor of Law, Vermont Law School.

The hearing will likely touch on a number of topics, including recent U.S. and global rulemakings on the liquidity coverage ratio and capital requirements set forth by the Basel Committee on Banking Supervision. SFIG looks forward to the testimony of its peer industry groups to promote rational capital and liquidity policies and will continue to engage Capitol Hill on these issues.

Back to top
 
PIMCO DECLARES “STORM IS BREWING” IN COMMERCIAL REAL ESTATE MARKET

According to a report released recently by Pacific Investment Management Co. (“PIMCO”), U.S. commercial real estate prices may fall as much as 5 percent in the next 12 months due to a tougher regulatory environment, a wall of debt maturities and property sales by publicly traded landlords. However, for flexible capital, the authors of the report say, these dislocations could create attractive investment opportunities, allowing some buyers to pick up properties at bargain prices. Furthermore, when a wave of maturing debt from the previous decade’s boom starts to come due this year, it could open up a window for investors to fund borrowers who come up short.

Back to top
 
NEW RMBS DEAL COMES TO MARKET BACKED BY MAJORITY NON-QM COLLATERAL

Originated by Caliber Home Loans, the $161.7 million COLT 2016-1 Mortgage Loan Trust “sailed through the market this week…to price the top piece…tight of guidance”, according to DebtWire

According to a Fitch Ratings Presale Report, it is the first transaction Fitch has rated collateralized with a majority of Non-QM mortgages, as defined by the ATR Rule. Fitch rated the most senior class “Asf”, with 44.7 percent credit enhancement, citing 100 percent full documentation and diligence review, the operational controls of the Originator, and the quality of the Servicer and Master Servicer as transaction positives but also cited non-QM and HPQM concentration, 47 percent of borrowers with recent credit events, loans with TRID exceptions, and a Rep and Warrant framework that did not include the automatic review of defaulted loans as transaction concerns.

Back to top
 
COINDESK: DAO ANALYSIS, LESSONS, AND RECOMMENDATIONS FOR FUTURE

According to a recent CoinDesk article, there is much to be learned from the recent DAO incident. The DAO, an ethereum-based distributed autonomous organization, has admitted becoming the victim of a cyberattack on their cryptocurrency Ether platform. In order to create a better future pertaining to DAOs, the CoinDesk article recommends instituting classes of smart contracts, instituting a self-imposed limit on any contract, and applying a trilogy of blockchain applications including business, technology and a legal aspect.

Blockchain technology has the potential to radically redefine many industries, including financial services. SFIG recognizes the importance of responsible development for this new technology and its applications, driving the formation of our Blockchain Task Force. If you would like to join this task force, please contact Alyssa.Acevedo@sfindustry.org.

Back to top
 
CFPB FINDS MORTGAGE SERVICERS CONTINUE TO USE FAILED TECHNOLOGY

Today, June 22nd, the Consumer Financial Protection Bureau (“CFPB”) issued a special issue of Supervisory Highlights which focused on its observations in mortgage servicing. According to the CFPB, some mortgage servicers continue to use failed technology that has already harmed consumers, putting them in violation of the CFPB’s new servicing rules, which took effect in January 2014. The report also discusses the CFPB’s approach mortgage to servicing exams, including a description of recent changes to the mortgage servicing chapter of the CFPB Supervision and Examination Manual.

Back to top
 
FRBNY: FHA SHOULD IMPOSE CAP ON BORROWERS’ DEFAULT RATES

According to a recent Federal Reserve Bank of New York (“FRBNY”) blog post, policy to increase homeownership rates should make homeownership not only more affordable but also more sustainable, which could be accomplished if the Federal Housing Administration (“FHA”) imposed a cap on borrowers’ cumulative default rates (“CDRs”) at the time of the mortgage origination. The FRBNY argues the expected CDR should reflect the borrower’s credit score, the loan-to-value ratio of the mortgage and the economic outlook. According to the blog’s authors, “An acceptable cap on the expected CDR should balance the benefits of increased access to homeownership against the personal and social costs of foreclosure when the homeownership ends in default. Affordability has the biggest impact if the household’s ownership experience is a success.”

Back to top
 
MARKET AND CENTRAL BANKS ON ALERT FOR BREXIT VOTE

Market participants are anxiously awaiting the results of a U.K. referendum that will show whether the nation has chosen to leave the EU (“Brexit”) on Thursday.

According to a recent Reuters’ article, an "out" Brexit vote would raise questions about the future of the EU, which accounts for nearly a quarter of global output. Reuters explains, with opinion polls showing support for "out" in the lead, central banks are nervously awaiting the outcome.

"Clearly this is a very important decision for the United Kingdom and for Europe," Federal Reserve Chair Janet Yellen said last Wednesday after the U.S. central bank kept interest rates on hold. "It is a decision that could have consequences for economic and financial conditions in global financial markets..[and] it could have consequences in turn for the U.S. economic outlook that would be a factor in deciding on the appropriate path of policy."

Back to top
 
SFIG COMMITTEES AND TASK FORCES

SFIG has a number of Committees and Task Forces meeting and working on many topics of interest to the securitization industry. Please email us for more information, including how to join.

SFIG is pleased to share this edition of its newsletter with our members, as well as our supporters in the structured finance community. To ensure that you receive future editions of the newsletter, please visit our website or email us to learn more about membership opportunities.

Contact Information

Richard Johns Executive Director

Kristi Leo Investor Relations

Sairah Burki Senior Director, ABS Policy

Dan Goodwin Director, Mortgage Policy

Tom McCrocklin Director, Advocacy

Jennifer Wolfe Manager, ABS Policy

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Senior Analyst, MBS Policy

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

Dani Hernandez Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

linkedin
Structured Finance Industry Group
WebsiteEmail Us | Web Archive
 
linkedin
wagers
Terms and Conditions | Privacy Policy