March 9, 2016 Newsletter
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March 9, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


Dear Friends and Colleagues,

Last week, I am happy to say we welcomed over 6,700 industry professionals registered for the ABS Vegas 2016 conference, the largest ever attendance for a capital markets conference in the world.

Once again, we were blessed with fantastic subject matter and panelists covering a range of relevant topics including some new ones like green bonds, fin-tech, Asia and Africa and expanding in other areas such as marketplace lending. We were treated with riveting keynote speeches from both Mohamed El-Erian and Michael Piwowar. And finally, let’s not forget the one-on-one meeting benefits, where I have heard from a number of institutions that their meeting totals reached an all-time high.

As I have mentioned before, when I receive numerous compliments on the success of the conference, I am humbled by such praise, as it is the industry itself that warrants that praise – we just go where the industry asks us.

On behalf of both SFIG staff and leadership, and our partners at IMN, I want to extend a huge “THANK YOU” for making this conference what it is.

For those who attended the conference, please remember that you may soon access conference presentations and panel recordings at IMN’s website, via the ABS Vegas 2016 agenda. We will send out a notification when these are available. Additionally, please do not hesitate to take advantage of the wealth of regulatory, legislative and industry information, guidance and comment on SFIG’s website. SFIG members can access member-only content by registering here.

Next stop – Structured Finance Canada on May 31st and June 1st! For more information, please click here. We hope to see you there!

Thank you again!

With kindest regards,

Richard Johns


Over 400 conference attendees registered for SFIG’s Women in Securitization (“WiS”) event at ABS Vegas. During the Winning Outside the Workplace event, participants had the opportunity to broaden their skills outside of the office place with a series of activities ranging from “conversation ice-breakers” and foreign language introductions to techniques for picking your way through a wine menu. The interactive and rotational aspect of the event where participants had to move from station to station drew significant praise and is certainly something we will look to repeat in the future.

Over the course of 2016 there will be several more events targeted towards promoting women through our WiS initiative and we thank our sponsors for helping to make this happen.

For further details on WiS and to register for the program, please sign up here. For opportunities to sponsor the WiS initiative, either personal or corporate, or to see a list of the current sponsors, please visit here.


As we were saddened to announce during ABS Vegas 2016, the industry is a much poorer place due to the passing of Reggie Imamura, after fighting illness.

In the spirit so often advocated by Reggie of “doing things well” we will not rush in our release of an article that truly does justice to the efforts of this incredible individual and crusader for this industry. Please look out for such a tribute in next week’s newsletter.

As a reminder, for those who would like to express their condolences we would invite you to visit, where you may pay homage with a message in your own words.


On March 2, 2016 the House Financial Services Committee approved H.R. 4166, the Expanding Proven Financing for American Employers Act with a bipartisan vote of 42-15. H.R. 4166, co-sponsored by Representatives Andy Barr (R-KY) and David Scott (D-GA), creates a workable risk retention regime for “qualified” collateralized loan obligations (“QCLOs”).

SFIG has been working with policymakers to urge the passage of the bill and looks forward to the CLO industry continuing to support real economy growth through investment in local businesses and communities, while also remaining true to the goals of risk retention.

To view the bills approved by the Committee and their vote totals, please click here.

To view SFIG letter on QCLO and CRE legislation, please click here.

To learn more about SFIG’s advocacy efforts, please contact


On March 2, 2016 the House Financial Services Committee also passed H.R. 4620, the Preserving Access to CRE Capital Act of 2016 by a bipartisan vote of 39-18. H.R. 4620 would exempt certain commercial mortgage backed securities (“CMBS”) from risk retention. The bill also allows for a pari-passu structure if two b-piece buyers fulfill the risk retention requirement under the final rule. The final rule allows a senior-subordinate structure for the b-piece retention option, and does not contemplate a pari-passu option.

SFIG’s membership has divergent opinions on H.R. 4620, as a majority of its investment-grade investors prefer the CMBS retention options as finalized under the risk retention rule, and do not support the legislation. Alternatively, SFIG’s issuer and b-piece buyer members are supportive of the adjustments to CMBS retention under H.R. 4620.

To view the bills approved by the Committee and their vote totals, please click here.

To view SFIG letter on QCLO and CRE legislation, please click here.

To learn more about SFIG’s advocacy efforts, please contact


U.S. Securities and Exchange Commission (“SEC”) Commissioner Michael S. Piwowar delivered keynote remarks at SFIG’s ABS Vegas 2016 conference last week, focusing on the benefits of the securitization market, the SEC’s recent actions with respect to securitizations and credit rating agencies, and observations of recent developments in European securitizations.

When assessing where the SEC should go from here, Piwowar recommended that the agency evaluate the cumulative impact of all the new rules (i.e. Dodd-Frank and Basel capital and liquidity regulations) on the securitization markets. The Commissioner highlighted the declining trend of securitization public offerings between 2014 and 2015 with a $22 billion decrease and this trend has continued through 2016. Piwowar stated:

We must appropriately regulate securitization offerings, including rules that adequately align the incentives of investors and sponsors. However, we must keep in mind that unnecessary or inappropriate regulation of securitizations may lead to less availability of capital, increased borrowing rates, and a more limited supply of credit. These effects are likely to be passed on to borrowers, either in terms of increased borrowing costs or loss of access to credit, and thus will cut directly against the benefits of securitization. 

To view Commissioner Piwowar’s keynote address, please click here. To view SFIG’s Executive Director Richard John’s testimony calling for a review of the combined effect of regulation on asset-backed securities liquidity, please click 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:

Enterprise Sales T-REX 03-04-2016
Associate Director/Director - Structured Finance - Model Management Fitch Ratings 02-29-2016
Credit Quant PeerIQ 02-22-2016
Mid-Level Corporate Trust Associate K&L Gates LLP 02-22-2016
Senior Analyst, Consumer ABS Kroll Bond Rating Agency 02-04-2016
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

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

For questions about positions at SFIG, please contact For questions about the website jobs portal, please contact


THURSDAY, March 10, 2016
3:00 p.m. – 4:00 p.m. (ET)

  • THURSDAY, March 10, 2016
    10:00 a.m. – 11:00 a.m. (ET)
  • THURSDAY, March 17, 2016
    10:00 a.m. – 11:00 a.m. (ET)

MONDAY, March 14, 2016
11:00 a.m. – 12:00 p.m. (ET)


MONDAY, March 14, 2016
2:00 p.m. – 3:00 p.m. (ET)


MONDAY, March 14, 2016
2:00 p.m. – 3:00 p.m. (ET)


MONDAY, March 14, 2016
4:00 p.m. – 5:00 p.m. (ET)


TUESDAY, March 15, 2016
11:00 a.m. – 12:00 p.m. (ET)


WEDNESDAY, March 16, 2016
2:00 p.m. – 3:00 p.m. (ET)


THURSDAY, March 17, 2016
2:00 p.m. – 3:00 p.m. (ET)


WEDNESDAY, March 16, 2016
12:00 p.m. – 5:00 p.m. (ET)
Hogan Lovells LLP
New York, NY
Note: Closed Meeting


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 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) Disclosure & 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.

Members interested in participating should contact

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

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

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

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 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 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 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

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

The Regulatory Capital and Liquidity Committee recently submitted 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”). 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

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.


According to a recent Reutersarticle, momentum for the proposed plan to relaunch ABS in Europe by lowering capital requirements for simple, transparent and standardized (“STS”) securitizations has come to a halt. The European Parliament will not vote on the plan before December, according to a member of the European Parliament, Paul Tang.

"We need a thorough technical analysis to make sure that we avoid the mistakes of the past," Tang explained. "We want to make sure that we have safe products."

Tang’s timetable anticipates talks with the European Commission (“EC”) on technical issues until the end of April with a report on the proposals prepared by the summer. The first vote of the Economic Affairs Committee of the European Parliament is scheduled for November.

The Parliament's final vote on the plan will be in December, but this remains to be confirmed in the timetable.

As Reuters explains, if the text adopted by lawmakers differs from the legislative proposals made by the EC and backed by EU states, a new set of open-ended negotiations among the EU institutions will have to start to agree to a common text.


The market for peer-to-peer lending, commonly referred to as marketplace lending, has reached the point in the U.K. that market participants expect the first European securitization of marketplace ABS to originate from the U.K. this year, according to a recent Bloomberg article. “[T]he region’s first sale of bonds tied to loans made via these online services could be just months away,” according to sources in the article at Moody’s and BBVA. The article describes market participants’ interest in these deals, quoting Aaron Baker, a BBVA Credit Analyst, indicating that “[a] multitude of funds are being built in order to invest in these products and banks are looking at how to provide finance to the sector.” In describing the role that securitization will have for funding growth in the sector, the articles states that “[s]ecuritization will be driven by hedge funds and other institutional investors looking to sell loans made via peer-to-peer services, rather than platform operators.”

The article also touches on the U.K. regulatory landscape for marketplace lending, highlighting that “the industry has moved to ease investor concerns with major U.K. operators regularly publishing loan-book data and default rates on their websites” and adding that as of 2014, the market has been regulated by the Financial Conduct Authority. On the evolution of banks’ involvement in the industry, Sachin Patel of Funding Circle stated that “[a]s the industry has evolved, so has its relationship with the banks […] Now we work together. Securitization is just the latest example of this.”


Themes are beginning to emerge from the responses to a European Commission (“EC”) consultation seeking to identify the collective impact of more than 40 regulations that the European Union has adopted during the financial crisis, according to a recent Bloomberg article.

Jonathan Hill, Commissioner of the EC, stated in a recent speech, “Respondents argue that in places our legislation is not sufficiently proportionate; that it could be weighing negatively on the amount of financing available to the wider economy; and that the compliance burden is too high.”

Hill has indicated that 40 percent of the filings focus on the interaction and unintended consequences of the mixture of regulations pushed through by the previous Commissioner.

The EC is expected to publish a summary of the responses in April and will hold a public hearing in May. The overall assessment will conclude by summer with results feeding into reviews of individual pieces of legislation and new legislation.


President Barack Obama met with Federal Reserve Chair Janet Yellen and U.S. Securities and Exchange Commission Chair Mary Jo White on Monday, March 7th to discuss implementing stronger protections for consumers and further financial regulation, according to a recent Bloomberg article.

The President defended the actions taken by the government in the wake of the crisis, including enacting the Dodd-Frank financial reform law and establishing the Consumer Financial Protection Bureau.

“I want to dispel the notion both on the left and on the right that after the financial crisis nothing happened,” Obama stated.

The administration has signaled it intends to keep tightening rules on the financial industry and is gearing up to release a new "fiduciary" rule relating to brokers’ handling of retirement accounts.


According to a recent article from National Mortgage News, on Monday, February 29th, a group of investors issued a set of “key principles” designed to add transparency to the PLS market. The document calls for an independent firm to act as a “deal agent” in certain private label RMBS transactions, having oversight over the other parties in each transaction.

According to National Mortgage News, the idea of an outside mediator is not new for investors. In fact, the concept of a deal agent has long been discussed at SFIG, which included a deal agent framework in its RMBS 3.0 Third Edition Green Papers published last November. The framework was the result of collaboration between issuers and investors across the industry. The RMBS 3.0 program continues to evolve that framework and will seek to take account of the principles released last week.

If you would like to participate in SFIG’s Project RMBS 3.0 and contribute to its forthcoming discussions on the deal agent, please email


In an effort to increase appetite for reinsurance, Freddie Mac announced on Monday, March 7th that the government-sponsored enterprise (“GSE”) has expanded the amount of loan level data it discloses about mortgages it insures. According to a recent article in National Mortgage News, the additional disclosures include quarterly updates on credit scores and loan-to-value ratios; loan-level details on mortgage insurance; identifying whether this insurance is paid by the lender or the borrower; and additional details about loan modifications, such as modification program, type and step-rate information.

Freddie Mac also announced its second offering this year of Structured Agency Credit Risk notes, meant to transfer some of the risk of default on loans it has securitized. According to Kevin Palmer, Senior Vice President of Credit Risk Transfer, “By providing more ongoing information, investors can better analyze our seasoned Credit Risk Transfer securities. Improved analytics reduces the uncertainty for internal valuation and secondary trading activities.”

To view the GSEs’ websites for credit risk transfers, please click here and here.


The Consumer Financial Protection Bureau (“CFPB”) announced on Monday, March 7th, that it is now accepting consumer complaints relating to online marketplace lending. It also released a consumer bulletin designed to educate consumers who are shopping for such loans. CFPB officials said they want to ensure that consumers know that marketplace lenders are required to follow all relevant federal and state consumer protection laws. "When consumers shop for a loan online we want them to be informed and to understand what they are signing up for…" CFPB Director Richard Cordray said in a press release.

The CFPB's press release defined a marketplace lender as a firm that "uses an online interface to connect consumers or businesses seeking to borrow money with investors willing to buy or invest in the loan." Some industry participants said the CFPB's bulletin suggested the agency may be skeptical of this young industry, while others welcomed the CFPB's actions.


On Monday, March 7th, Federal Reserve Governor Lael Brainard highlighted the liquidity issues in the bond market during her speech, “An Update on the Outlook, Liquidity, and Resilience.” Brainard recognized that there are some liquidity strains, especially in the high-yield bond market, but noted that these are worth the increased security offered by banks holding fewer risky assets, according to a recent Business Insider article.

"While acknowledging the role of regulation as a possible contributor, it is important to recognize that this regulation was designed to reduce the concentration of liquidity risk on the balance sheets of the large, interconnected banking organizations that proved to be a major amplifier of financial instability at the height of the crisis," said Brainard.

She went on to concede that, "there may be some deterioration in the resilience of liquidity at times of stress, along with a greater incidence of outsized intraday price movements... Relatedly, liquidity appears to be more segmented based on the characteristics of the securities being traded and the underlying structure of the markets in which they are traded."


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

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

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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