June 24, 2015 Newsletter
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June 24, 2015

SFIG Calendar

Advocacy Outlook

Industry News Highlights


With the release of the U.S. Securities and Exchange Commission’s (“SEC”) Regulation AB II final rule in August of 2014, disclosure and reporting requirements for registered offerings of ABS were substantially revised and several key areas of reform were implemented.

However, the SEC deferred action on several important aspects of its rule proposals, including asset-level information for additional asset classes. In particular, action was deferred on the SEC’s proposal to require asset‑level information for asset classes beyond those identified in the final rules (residential mortgages, commercial mortgages, auto loans, auto leases, and debt repackagings including resecuritizations).

A total of 6,905 SFIG members spent nearly 125 hours on 170 Regulation AB II conference calls to identify and address key questions and build consensus. Through these discussions, SFIG members developed a comment letter regarding disclosure requirements that was submitted to the SEC yesterday, June 23rd.

Future discussions within the asset-level committees and Regulation AB II Task Force will focus on the remaining outstanding proposed rules, starting with the potential expansion of disclosure and reporting requirements to the 144A market. If you would like to participate in these discussions, please contact Alyssa.Acevedo@sfindustry.org.

THURSDAY, June 25, 2015
10:00 a.m. – 11:00 a.m. (ET)

THURSDAY, June 30, 2015
10:00 a.m. – 11:00 a.m. (ET)

THURSDAY, July 2, 2015
10:00 a.m. – 11:00 a.m. (ET)
MONDAY, June 29, 2015
2:00 p.m. – 3:00 p.m. (ET)
TUESDAY, June 30, 2015
11:00 a.m. – 12:00 p.m. (ET)
TUESDAY, June 30, 2015
12:00 p.m. – 1:00 p.m. (ET)
THURSDAY, July 2, 2015
11:00 a.m. – 12:00 p.m. (ET)
WEDNESDAY, September 16, 2015 – FRIDAY, September 18, 2015
The Fontainebleau
Miami Beach, FL
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.

The RMBS 3.0 Task Force released its Second Edition RMBS 3.0 Green Paper in November. Following the successful SFIG/IMN Private Label RMBS Symposium, the task force will continue its efforts to address key issues specific to private label mortgage securities through work streams relating to (1) Representations, Warranties, and Repurchase Enforcement; (2) Due Diligence, Data, and Loan-Level Disclosure; and (3) Role of Transaction Parties and Bondholder Communications. Presently, the task force is working on (1) developing a comprehensive compilation of representations and warranties for release in the spring of 2015 and (2) a grid summarizing roles of transaction parties. We encourage members to participate in any or all of the working groups to contribute towards the mission of RMBS 3.0.

For additional information on RMBS 3.0, or to join the task force, please contact Mary.Robinson@sfindustry.org.

The GSE Reform Task Force is in the process of reviewing the FHFA’s update to the single security initiative and expects to submit a comment letter. The task force has also formed policy positions on the Carney-Delaney-Himes GSE Reform bill and updated its briefing book to support its advocacy efforts. With the release of the bill, SFIG staff also updated its GSE Reform Legislative Comparison, which analyzes key provisions in the five most recent housing finance reform bills including the Johnson-Crapo bill and the PATH Act. SFIG staff previously summarized members’ recommendations on the former in a briefing book, and plan to produce a similar book on the latter in the upcoming months. Additionally, the task force has been actively engaging the Federal Housing Finance Agency on several fronts, with comments submitted on its single security proposal, guarantee fee pricing and Strategic Plan for 2015-2019.

To join SFIG’s GSE Reform Task Force and learn more, please contact 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 of 2014. SFIG also continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. We 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 Alyssa.Acevedo@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 Amanda.Bateman@sfindustry.org to participate on the Task Force.

The Risk Retention Industry Guide Work stream is 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.

SFIG’s Shadow Banking Task Force has established the following agenda:

  • Leverage the predictive powers of the G20’s shadow banking initiative to determine future SFIG advocacy initiatives
  • Assess the level of regulation to which our members are already subject
  • Measure the full impact of those regulations on lending decisions and business models
  • Provide input into IOSCO, BCBS and IAIS on the revitalization of securitization markets

The task force will have its first full meeting in the coming weeks, and members from across asset classes are encouraged to participate.

To register your interest in SFIG’s Shadow Banking Initiative, please contact Amanda.Bateman@sfindustry.org.

The Regulation AB II Task Force will focus on the disclosure and offering process requirements within the final rule. Two work streams have been formed to develop a comment letter on the proposed rules that remain outstanding and to produce an industry guide for critical elements of the final rule. SFIG submitted the first portion of this comment letter to the SEC regarding asset-level disclosure on June 23rd. 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 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 rule or NSFR, please contact Alyssa.Acevedo@sfindustry.org.

The Derivatives in Securitization Task Force recently obtained no-action relief from the CFTC giving swap dealers comfort that the CFTC would not take enforcement action against swap dealers that did not comply with certain CFTC Regulations when taking actions in response to the credit ratings downgrade of a counterparty to a legacy swap. The relief applies to swaps with SPVs that were in existence prior to October 10, 2013. The task force also commented on the CFTC’s proposal on margin requirements for uncleared swaps, as well as the prudential regulators’ proposal regarding margin and capital requirements for covered swap entities.

SFIG members who are interested in learning more about this initiative should email Amanda.Bateman@sfindustry.org.

The Money Market Fund Reform Working Group submitted a comment letter on October 13, 2014 regarding the Securities and Exchange Commission’s July 23, 2014 proposal which includes, among other things, possibly amending rule 2a-7’s issuer diversification provisions to eliminate an exclusion that is currently available for securities subject to a guarantee issued by a non-controlled person. SFIG also submitted a comment letter in September 2013 on Money Market Fund Reform.

If you are interested in joining this working group, please contact Alyssa.Acevedo@sfindustry.org.

The High Quality Securitization ("HQS”) Task Force responded to the European Commission’s consultation on an EU framework for simple, transparent and standardized securitization on May 12, 2015. The task force also previously responded to the BCBS-IOSCO consultation on its criteria for identifying simple, transparent and comparable securitizations. SFIG’s comments were built off of those sent to the European Banking Authority on January 14th (available here) regarding its proposed criteria and to the European Central Bank and Bank of England last summer (available here) regarding the development of a sustainable securitization market in Europe.

To join the HQS Task Force, please contact Amanda.Bateman@sfindustry.org.


In his remarks at Global ABS in Barcelona on June 17th, Bank of England’s (“BoE”) Executive Director for Prudential Policy David Rule told audiences that while he believes the Basel Committee on Banking Supervision calibrated the bank capital requirements “broadly right” in its final framework, there is a case for granting some relief to simple, transparent and comparable (“STC”) transactions. According to Rule, STC securitizations may warrant lower capital requirements due to their potentially lower structure risk.

Notably, Rule’s remarks also addressed the BoE’s view on the implementation process for the STC designation, stating the primary obligation should be on the originator to attest compliance with the criteria. Furthermore, he described the importance of not labeling all non-STC transactions as “bad” as there should be a continuing place in the market for many transactions that do not qualify as such, including synthetic transactions, managed portfolios and pools that do not meet granularity requirements.


The China Banking Regulatory Commission (“CBRC”) has relaxed its rules for approving ABS plans, according to a June 18th Reuters article. The CBRC is now allowing local provincial bank regulators to approve Chinese city commercial banks’ new issuance. However, large commercial Chinese banks are still required to seek approval from the CBRC for new ABS issuance.

This is the latest effort by Chinese regulators to expand securitization, as previously reported by SFIG, and ultimately to lower financing costs for companies and increase investment opportunities.

If you are interested in joining SFIG’s Chinese Market Committee, please contact Alyssa.Acevedo@sfindustry.org.


Earlier this week, Freddie Mac announced the release of its Single Security and Common Securitization (“CSP”) Platform webpage. The website provides an overview of the Single Security/CSP joint initiative between Freddie Mac and Fannie Mae. Information on the website will include updates on the development of the Single Security and CSP, as well as means of electronically submitting questions and subscribing to receive email updates on the joint initiatives. Fannie Mae hosts a similar site


The Consumer Financial Protection Bureau (“CFPB”) is delaying the effective date of the TILA-RESPA Integrated Disclosure Act (“TRID”) implementation until October 3, 2015. The delay in TRID implementation comes as a result of an administrative error wherein the CFPB failed to meet filing requirements of the Congressional Review Act which dictate that the Government Accountability Office must receive any new rule at least 60 days before its effective date. CFPB’s Director Richard Cordray issued a statement last week noting that the agency further believes that “the additional time included in the proposal effective date would better accommodate the interests of many consumers and providers…”


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 Director of ABS Policy

Michael Flood Director of Advocacy

Mary Robinson Policy Manager

Alyssa Acevedo Policy Analyst

Amanda Bateman Policy Analyst

Daniel Tees Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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