May 11, 2016 Newsletter
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May 11, 2016
 
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
CFPB PROPOSES RULE PROHIBITING MANDATORY ARBITRATION CLAUSES; SFIG TO FORM TASK FORCE

Last Thursday, May 5th, the Consumer Financial Protection Bureau (“CFPB”) released a proposed rule that would prohibit companies from using mandatory arbitration clauses that prevent class action lawsuits in new contracts with consumers.

The CFPB Director, Richard Cordray, explained during prepared remarks that companies would still be able to include arbitration clauses in their contracts, but for contracts subject to the proposal, the “clauses would have to say explicitly that they cannot be used to stop consumers from grouping together in a class action.” The proposal would provide the specific language that companies must use. The proposal would also require companies that use pre-dispute arbitration agreements to submit claims, awards, and certain related materials filed in arbitration cases to the CFPB so that they may monitor the process. The CFPB is also considering publishing the collected information so the public can monitor the arbitration process as well.

SFIG will be forming a task force to evaluate the proposal and determine SFIG's potential response. If you are interested in participating, please contact Alyssa.Acevedo@sfindustry.org or Jennifer.Wolfe@sfindustry.org.

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SPEAKERS ANNOUNCED FOR “WiS” EVENT IN TORONTO

SFIG and Women in Securitization (“WiS”) are pleased to announce the participation of the following senior leaders in the securitization industry at the panel discussion on May 31st:

  • Susan Calder: Director, Securitization Finance at RBC Capital Markets
  • Paula Cruickshank: Vice President, Securitization at Business Development Bank of Canada
  • Marc MacMullin: Partner & Co-Head of Structured Finance at McCarthy Tétrault LLP
  • Susan Thomas: Associate General Counsel at Ford Motor Credit Co.

The panel will be followed by a reception graciously hosted by McCarthy Tétrault LLP.

Please register for the WiS Toronto event here.

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SFIG TRID PROPOSAL ADEQUATELY ADDRESSES RISK

According to a recent report from Moody’s Investors Service, SFIG’s draft proposal on a standardized approach to the scope of review for TILA-RESPA Integrated Disclosure (“TRID”) exceptions “is adequate to identify those compliance risks that are likely to cause losses to residential mortgage-backed securitization (RMBS) trusts, aside from one grading provision with which [Moody’s] disagree[s].” As SFIG noted in its announcement of the proposal in March, this draft assumes TRID is interpreted by regulators and courts in accordance with the principles of liability set forth in a December 29, 2015 letter from Richard Cordray, the Director of the CFPB. Consequently, Moody’s notes that some of the proposal’s legal positions are subject to uncertainty pending additional guidance from the CFPB. However, Moody’s concludes that the CFPB’s decision to re-open TRID will likely benefit SFIG’s efforts to standardize compliance with the rulemaking.

Please contact Daniel.Goodwin@sfindustry.org with questions regarding TRID.

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SFIG’S MARKETPLACE COMMITTEE WILL RESPOND TO OCC’S “FINTECH” WHITE PAPER

On March 31, 2016, the Office of the Comptroller of the Currency (the “OCC”) issued a white paper describing the eight guiding principles the OCC proposes to follow in the regulation of financial technology. The eight principles presented in the white paper are: 1) support responsible innovation; 2) foster an internal culture receptive to responsible innovation; 3) leverage agency experience and expertise; 4) encourage responsible innovation that provides fair access to financial services and fair treatment of consumers; 5) further safe and sound operations through effective risk management; 6) encourage banks of all sizes to integrate responsible innovation into their strategic planning; 7) promote ongoing dialogue through formal outreach; and 8) collaborate with other regulators.

SFIG’s Marketplace Lending Committee is currently crafting a response to the white paper, and comments are due on May 31, 2016.

If you would like to join the Marketplace Lending Committee, please contact Jennifer.Wolfe@sfindustry.org or Alyssa.Acevedo@sfindustry.org.

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SFIG TO COMMENT ON FRB PROPOSED SINGLE COUNTERPARTY CREDIT LIMITS

SFIG’s Regulatory Capital & Liquidity Committee will be commenting on the Federal Reserve’s (“FRB”) proposed rule to address the risk associated with excessive credit exposures of large banking organizations to a single counterparty. As the FRB explained, the proposal would apply single-counterparty credit limits to bank holding companies with total consolidated assets of $50 billion or more and the proposed limits “are tailored to increase in stringency as the systemic footprint of a firm increases.”

Comments on the proposed rule are due by June 3rd. If you would like to join SFIG’s Regulatory Capital & Liquidity Committee, please contact Alyssa.Acevedo@sfindustry.org.

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SFIG TO SUBMIT COMMENTS ON BCBS REVISIONS TO THE LEVERAGE RATIO FRAMEWORK

Last month, the Basel Committee on Banking Supervision (“BCBS”) released a consultative document on revisions to the Basel III leverage ratio framework. The proposed revisions affect the “design and calibration” of the leverage ratio framework and have been “informed by the monitoring process in the parallel run period since 2013, by feedback from market participants and stakeholders and by the frequently asked questions process since the January 2014 release of the standard  Basel III leverage ratio framework and disclosure requirements.”

SFIG’s Regulatory Capital and Liquidity Committee will be submitting comments to the BCBS regarding revisions that might impact securitization. Please contact Alyssa Acevedo if you are interested in participating.

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BLOCKCHAIN – FIND OUT WHAT THE FUSS IS ABOUT!

As shared in our Newsletter last week, SFIG is pleased to announce the formation of our Blockchain Task Force.

The mission of the task force will be to identify and enable opportunities where blockchain may enhance execution efficiency, capital markets transparency, investor confidence, and sustainable liquidity driven by four core focus areas: (1) Education, (2) Advocacy, (3) Ecosystem Development and (4) Application and Use Cases. The co-chairs of the task force include Lewis Cohen, Hogan Lovells US LLP and Lisa Hernandez, Deloitte & Touche LLP.

In conjunction with our Task Force, we have also launched a Blockchain Symposia Series, with the following four dates:

Tuesday, May 24th – D.C.
Dentons
1900 K Street NW
Washington DC 20006
Registration available here.

Panelists include, among others:

  • David Beam, Partner, Mayer Brown LLP
  • Greg Lumelsky, Assistant General Counsel, Bank of America
  • Matt Mulder, Chief Counsel and Legislative Director, Rep. Patrick McHenry, U.S. House of Representatives
  • Prakash Santhana, Director Payments Integrity, Cyber Risk Services, Deloitte Financial Advisory Services LLP

Tuesday, June 7th – New York
Registration forthcoming.

Tuesday, October 4th – New York
Registration forthcoming.

Thursday, October 6th – D.C.
Registration forthcoming.

Please note that these events are closed to the press.

If you would like to be included in the newly created Blockchain Task Force, please email Alyssa.Acevedo@sfindustry.org.

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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, enthusiastic, hard-working, 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 Data/Policy Analysts to Director of Advocacy. 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
Enterprise Sales T-REX 03-04-2016
Associate Director/Director - Structured Finance - Model Management Fitch Ratings 02-29-2016
Mid-Level Corporate Trust Associate K&L Gates LLP 02-22-2016

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.

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SFIG CALENDAR
MEETINGS
WEEKLY CREDIT CARD ISSUER COMMITTEE CALLS
  • THURSDAY, May 12, 2016
    10:00 a.m. – 11:00 a.m. (ET)
  • THURSDAY, May 19, 2016
    10:00 a.m. – 11:00 a.m. (ET)
 
 
LEGAL COUNSEL COMMITTEE CALL

FRIDAY, May 13, 2016
12:00 p.m. – 1:00 p.m. (ET)

 
 
BIWEEKLY RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, May 17, 2016
11:00 a.m. – 12:00 p.m. (ET)

 
 
MASTER SERVICER AND SERVICER SUBCOMMITTEE CALL

TUESDAY, May 17, 2016
1:00 p.m. – 2:00 p.m. (ET)

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EVENTS
SFIG WiS EVENT: WOMEN AT THE INTERSECTION OF FINANCE AND POLICY

THURSDAY, May 12, 2016
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Ave NW
Washington, DC
Registration available here.

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IMN’s INVESTORS CONFERENCE ON CLOs AND LEVERAGED LOANS

MONDAY, May 16, 2016 – TUESDAY, May 17, 2016
Grand Hyatt New York
New York, NY
Registration available here.

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SFIG D.C. SYMPOSIUM ON BLOCKCHAIN TECHNOLOGY

TUESDAY, May 24, 2016
Dentons
1900 K Street NW
Washington DC 20006
Registration available here.

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SFIG WiS EVENT IN TORONTO

TUESDAY, May 31, 2016
McCarthy Tétrault LLP
TD Bank Tower, 53rd floor
66 Wellington Street West
Toronto, Ontario M5K 1E6
Registration available here.

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SFIG & IMN's STRUCTURED FINANCE CANADA 2016

TUESDAY, May 31, 2016 – WEDNESDAY, June 1, 2016
Hyatt Regency Toronto
Toronto, Ontario
Registration available here.

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IMN’s GLOBAL ABS 2016 CONFERENCE

TUESDAY, June 14, 2015 – THURSDAY, June 16, 2016
The Barcelona International Convention Centre
Barcelona, Spain
Registration available here.

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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 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 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.

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INDUSTRY NEWS HIGHLIGHTS
U.S. TREASURY PUBLISHES WHITE PAPER ON MARKETPLACE LENDING

Yesterday, May 10, 2016, the U.S. Treasury Department published a white paper on the marketplace lending industry. The paper is titled, “Opportunities and Challenges in Online Marketplace Lending,” and provides an overview of the comments the Treasury Department received in response to its Request for Information issued in August 2015. According to the Treasury Department’s executive summary, the “white paper establishes an overview of the evolving market landscape, reviews stakeholder opinions, and provides policy recommendations.” The publication acknowledges the benefits and risks associated with marketplace lending, and “highlights certain best practices applicable both to established and emerging market participants”. The paper presents the following recommendations for both the federal govern­ment as well as private sector participants:

1. Support more robust small business borrower protections and effective oversight;
2. Ensure sound borrower experience and back-end operations;
3. Promote a transparent marketplace for borrowers and investors;
4. Expand access to credit through partnerships that ensure safe and affordable credit;
5. Support the expansion of safe and affordable credit through access to government-held data; and
6. Facilitate interagency coordination through the creation of a standing working group for online marketplace lending.

SFIG’s Marketplace Lending Committee responded to the Treasury Department’s Request for Information in September 2015. The Marketplace Lending Committee’s agenda has now advanced to the establishment and documentation of recommended market best practices. The Best Practices initiative has established five work streams, and more information about the initiative may be found here.

If you would like to join the Marketplace Lending Committee, please contact Jennifer.Wolfe@sfindustry.org or Alyssa.Acevedo@sfindustry.org.

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ONLINE LENDERS GET BURNED BETTING ON IVY LEAGUERS

According to a Wall Street Journal article, online lenders' business model of targeting Ivy League student borrowers is starting to backfire. The lenders initially targeted borrowers from elite schools because of their anticipated low default rates, focusing on those with graduate degrees, high credit scores and high incomes. Some loans were offered at a lower interest rate than the federal government or large private lenders charged to attract those student customers. But these borrowers are proving especially keen to pay off their debt faster than the lenders expect. Darien Rowayton Bank in Darien, Conn., has a national online lending platform where it says student-debt borrowers are paying 15% to 17% more than they are obligated each month. Gary Lieberman, chairman of the Bank, said “the nature of these borrowers is that they really want to pay off their debt.”

As marketplace lenders sell most of their loans to investors instead of holding them like traditional banks, the thinking is that investors will perceive these loans to be more reliable. But the seemingly anti-debt attitude of student borrowers could make business difficult for lenders and leave some investors at risk of collecting less in interest payments. “Prepayment risk,” said David Varano, an analyst at Interactive Data, a firm that provides fixed-income valuations, “is likely one of the factors making its way into the market.”

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VOLATILITY DRIVING TRADERS AWAY FROM FINANCIAL MARKETS

According to a recent Bloomberg article, the increased volatility in stocks, currencies and bonds is driving traders away from financial markets. While U.S. equities have recently rebounded, volume in the S&P 500 is down. Regarding currencies, speculative bets have dropped to the lowest levels in two years and average daily trading of U.S. Treasuries is nearing a seven-year low. The state of the industry has been described by some bankers as one of “paralyzing volatility” in which clients are being chased away, causing industry-wide trading revenue to plunge to its lowest level since 2009. While a rise in volatility usually leads to higher trading activity, according to the article, “violent swings across assets have whipsawed just about everyone as concern deepens over global growth and the effectiveness of negative interest rates and quantitative easing.” As a result, certain banks are saying they are focusing their business on wealth management rather than trading or making markets.

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CONSUMER CREDIT GROWS AT FASTEST PACE SINCE 2001 IN MARCH

Last week, the U.S. Federal Reserve released data which showed that in March 2016, consumer credit outstanding grew at its fastest pace since 2001, increasing $29.6 billion to $3.59 trillion. The total percent change based on an annual rate was 10 percent for the month. Significantly, revolving credit grew at an annualized pace of 14.2 percent, reaching 951.6 billion, whereas compared to the previous month it only grew at a rate of 3.7 percent. Nonrevolving credit grew at an annualized pace of 8.5 percent versus 4.2 percent in February. According to Standard & Poor’s, the data shows growth in the student loan sector, where loans outstanding grew $31.7 billion to $1.35 trillion, and the auto sector, where loans outstanding grew $13.5 billion to $1.05 trillion. According to S&P, “these are substantial increases that suggest household credit utilization is picking up and may yet support the economy.”

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INDUSTRY AGREES TREASURY BOND MARKET NEEDS BETTER OVERSIGHT

According to a Bloomberg article, concerns about the splintering $13.4 trillion Treasury bond market emerged in responses to a recent Treasury Department survey on the market’s structure, and industry participants agree that more coordinated oversight of the market is needed.    

Earlier this year, on January 22, 2016, the Treasury published a Request for Information on the Treasury bond market, including structural changes, trading and risk management practices, market data and public disclosure. Recent ‘flash’ crashes and rallies, alleged manipulation in the Treasury bond market and the increase in high frequency trading motivated the inquiry. Among the 52 responses the Treasury received, industry participants centered around which activities should get more regulation as the market changes due to technological advancement and balance-sheet pressures.

Some industry groups generally agreed that more coordinated oversight of the Treasury market is needed in order to ensure liquidity. In a letter to the Treasury, the Federal Reserve Bank of Chicago said, “The Treasury market has historically been a lightly regulated marketplace… it is still unclear what authority primarily regulates the U.S. cash Treasury market and has the right to bring enforcement cases.”

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OFR REPORT EXAMINES IMPACT OF BANKS’ LENDING STANDARDS ON AVAILABILITY OF MORTGAGE LOANS

According to a report published today by the Office of Financial Research (“OFR”), changes in credit standards reported in the Federal Reserve’s quarterly Senior Loan Officer Opinion Survey are a leading indicator of the financial industry’s vulnerability to shocks. The report, entitled The Real Consequences of Bank Mortgage Lending, matched responses to the survey with mortgage application information from the Home Mortgage Disclosure Act (“HMDA”) between 1990 and 2013.

The HMDA data containing both accepted and denied applications enabled the OFR to observe changes in denial rates concurrent with changing standards reported by loan offices. The OFR found that “reports of tightened standards are associated with an increase of about 1 percentage point in denial rates (conditioning on changes in macroeconomic conditions and borrower credit quality), implying a reduction in aggregate mortgage credit of about $690 million per quarter.”

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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

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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