May 21, 2014 Newsletter
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May 21, 2014
 

SFIG News

SFIG Calendar

Advocacy Outlook

Recent Developments

Upcoming Events in Washington

 
SFIG NEWS
SFIG JOINS ABS EAST AS LEAD ASSOCIATION PARTNER
The Structured Finance Industry Group (SFIG) is excited to announce its role as Lead Association Partner of IMN's ABS East Conference. The event, taking place September 21-23, 2014 in Miami, has served as the must-attend Fall gathering for the structured finance community and we are especially excited to be a part of its 20th anniversary.

Hosting a delegation of over 3,000 structured finance and securitization professionals, including more than 1,000 attendees from issuers and investors, ABS East 2014 will provide comprehensive coverage on the revival and strengthening of the US securitization market, along with what our markets should look like in the future, given the importance of securitization to the real economy.

We believe SFIG’s participation at ABS East will further extend members’ meaningful educational opportunities and provide a beneficial platform to openly discuss the securitization market and financial sector as a whole.

We hope to see you in Miami this September.

 
 
SFIG HOLDS SPRING SYMPOSIUM FEATURING REGULATION AB II PANEL
On May 15, 2014, SFIG hosted its Spring Symposium in New York City, kindly hosted by Societe Generale. After introductory remarks by Executive Director Richard Johns, Stephen Gallagher, Head of Research at Societe Generale, shared his outlook on the U.S. economy. Steve Kudenholdt, a partner with Dentons, then moderated a panel on Regulation AB II, composed of the following panelists of SFIG members: Bob Behal (Vanguard), Myoungsu Kong (Citigroup), Bonnie Seideman (GE Capital), and Ned Myers (Lewtan). The panel discussion featured a lively exchange of member opinions on the asset level disclosure proposal reopened by the Securities Exchange Commission in late February.

Please click here for the comment letter submitted by SFIG on April 28, 2014. For questions on SFIG’s Regulation AB II advocacy, please contact Sairah.Burki@sfindusty.org.

 
 
SFIG TO SUBMIT COMMENT LETTER ON END-USER EXEMPTION FOR SPV SWAPS
The Derivatives in Securitization Task Force will submit a comment letter to advocate the need for an end-user exemption for special purpose vehicle (SPV) swaps from the forthcoming reproposal on margin rules for uncleared swaps. It is the task force’s intention to submit its letter before the reproposal is issued. If you would like to join the Derivatives in Securitization Task Force and take part in the comment letter process, please contact Amanda.Bateman@sfindustry.org.
 
 
SFIG CALENDAR
PROJECT RMBS 3.0 REPRESENTATIONS, WARRANTIES, AND REPURCHASE ENFORCEMENT WORKING GROUP CONFERENCE CALL (BI-WEEKLY)
THURSDAY, MAY 22, 2014
4:00 p.m. – 5:00 p.m. (EST)
 
 
PROJECT RMBS 3.0 DUE DILIGENCE, DATA AND DISCLOSURES WORKING GROUP CONFERENCE CALL (BI-WEEKLY)
THURSDAY, MAY 29, 2014
4:00 p.m. – 5:00 p.m. (EST)
 
 
IMN 2014 GLOBAL ABS CONFERENCE
TUESDAY, June 10, 2014 – THURSDAY, June 12, 2014
Barcelona International Convention Centre
Barcelona, Spain
Registration available here
 
 
SFIG BOARD OF DIRECTORS MEETING Q2’14
TUESDAY, June 24, 2014
12:00 p.m. – 5:00 p.m. (EST)
New York, NY
Note: Closed Meeting
 
 
IMN ABS EAST 2014 CONFERENCE (SFIG-LEAD ASSOCIATION PARTNER)
SUNDAY, September 21, 2014 – TUESDAY, September 23, 2014
The Fontainebleau Hotel
Miami Beach, FL
Registration available here
 
 
SFIG & IMN ABS VEGAS 2015
SUNDAY, February 8, 2015 – WEDNESDAY, February 11, 2015
The Aria Resort and Casino
Las Vegas, NV
Registration available here
 
 
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.

Project RMBS 3.0 continues to work towards bringing private label securities back to the mortgage market. Working Groups conduct regular meetings via conference call to address issues specific to private label mortgage securities in the following categories: 1) Representations, Warranties and Repurchase Enforcement; 2) Due Diligence/Loan Review, Data and Disclosure; and 3) Role of Trustees and Bondholder Communications. We encourage members to participate in any or all of the Working Groups to contribute towards the mission of Project RMBS 3.0. Please contact Mary.Robinson@sfindustry.org to join a Working Group or with any additional questions on Project RMBS 3.0.

The GSE Reform Task Force recently finalized SFIG’s policy positions as they relate to the proposed Johnson-Crapo legislation for housing finance reform, which was recently approved by the Senate Committee on Banking, Housing, and Urban Affairs by a 13-9 vote. SFIG’s GSE Reform Task Force has met regularly since the bill was initially released and will reconvene in the event Senator Harry Reid brings the bill to a vote by the Senate. Until then, SFIG is currently reviewing the PATH Act in preparation for any action the House Financial Services Committee may take on housing finance reform. If you would like to learn more about SFIG’s activities with respect to GSE Reform, please contact Amanda.Bateman@sfindustry.org.

The Mortgage Loan-Level Disclosure Subcommittee has reviewed and developed additional data elements for potential disclosure. SFIG will use this work as a basis of discussions and correspondence with the Securities and Exchange Commission on the mortgage aspects of Regulation AB II. SFIG continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. Please contact Alyssa.Acevedo@sfindustry.org for additional information on SFIG’s work on this topic.

SFIG’s Credit Card Committee is meeting via conference call to develop a response to Moody’s Request for Comment (RFC) on the Approach to Rating Credit Card Receivables-Backed Securities. Comments are due June 9, 2014. To participate in the comment letter process additional information on the Credit Card Committee response to Moody’s RFC please contact Mary.Robinson@sfindustry.org.

The Volcker Task Force is working with SFIG’s various asset class committees to determine key issues and the need for interpretative guidance regarding the Volcker Rule. Please contact Amanda.Bateman@sfindustry.org for additional information on the Volcker Task Force.

The Risk Retention Committee is continuing to follow up with regulators on risk retention questions across asset classes. Topics currently under discussion include participations and representative sample approaches. Please contact Alyssa.Acevedo@sfindustry.org with any questions.

SFIG is continuing to build membership for its Chinese Market Committee. If you would like more information on SFIG’s work with respect to Chinese securitization, please contact Alyssa.Acevedo@sfindustry.org.

SFIG has launched its initiative to provide critically needed input for the Financial Stability Board’s “Shadow Banking” project. For more information on SFIG’s work on Shadow Banking, please contact Amanda.Bateman@sfindustry.org.

The Derivatives in Securitization Task Force recently met with the Commodity Futures Trading Commission to discuss a no-action request regarding enforcement against a registered swap dealer for failing to comply with regulations that may become applicable to legacy SPV swaps pursuant to a credit rating downgrade of a swap dealer on May 13th. The task force will submit a comment letter to advocate the need for an end-user exemption for special purpose vehicle (SPV) swaps from the forthcoming reproposal on margin rules for uncleared swaps. SFIG members who are interested in participating in this initiative should email Amanda.Bateman@sfindustry.org.
 
 
RECENT DEVELOPMENTS
PRELIMINARY EUROPEAN LCR PROPOSALS RAISE QUESTIONS ON IMPACT TO ABS
European Commission (EC) member states are meeting informally to discuss preliminary proposals on the draft Liquidity Coverage Ratio (LCR) released by the EC that would widen the scope of ABS that qualifies for higher liquidity treatment. The EC proposal would count auto, SME and consumer loan backed ABS as Level 2B assets, with a 25 percent haircut. The haircut for the most liquid covered bonds would drop from 15 to 7 percent. The draft proposal would require that ABS be rated AA- or above to qualify.

The EC proposal would allow the “competent authority,” or national policymakers, to make determinations as to the loan-to-value (LTV) thresholds; under the Basel LCR framework, the ABS LTV threshold is pre-set at 80 percent.

Industry participants note that because the draft proposals were circulated to representatives from the impacted sectors there is still ample opportunity to advocate for the most appropriate LCR definition.

The EC proposal would also provide better treatment for RMBS backed by guaranteed loans, which would qualify as highly liquid.

 
 
SENATE BANKING COMMITTEE PASSES HOUSING FINANCE REFORM LEGISLATION BY A MARGIN OF 13-9
The Senate Committee on Banking, Housing, and Urban Affairs (Committee) passed S.1217, the Housing Finance Reform and Taxpayer Protection Act, as amended, by a vote of 13-9. Chairman of the Committee, Senator Tim Johnson (D-SD), and Ranking Member, Senator Mike Crapo (R-ID), introduced legislation to reform the U.S. housing finance system by winding down Fannie Mae and Freddie Mac and replacing them with a new system in which private capital would be in a first loss position prior to a catastrophic government guarantee being made available. This system would be regulated by the newly-created Federal Mortgage Insurance Corporation and backstopped by an explicit guarantee from a Mortgage Insurance Fund. The legislation builds upon a previous bill authored by Senators Bob Corker (R-TN) and Mark Warner (D-VA).

Two manager’s amendments, no. 2 and no. 98, passed the Committee to amend the bill. Summaries of these amendments are available here. An amendment that would prohibit federal entities from purchasing or insuring mortgage loans in municipalities that use eminent domain to seize underwater mortgages was defeated by the Committee in a 14-8 vote. With its passage by the Committee, the next question regarding GSE reform is whether Senate Majority Leader Harry Reid (D-NV) will bring the bill to a vote by the full Senate.

Please contact Amanda.Bateman@sifndustry.org if you would like to participate on SFIG’s GSE Reform Task Force.

 
 
FSOC PUBLIC CONFERENCE ON ASSET MANAGEMENT
On Monday, the Financial Stability Oversight Council (FSOC) held a public conference to review potential risks posed by the asset management industry to the U.S. financial system. During her opening remarks, Treasury’s Under Secretary for Domestic Finance Mary Miller told attendees that FSOC has been authorized to take a number of policy responses if it determines those risks require action, which can include designating asset management firms as Systemically Important Financial Institutions (SIFIs). Miller noted FSOC’s authorities “include highlighting potential emerging threats in its annual reports to Congress, making recommendations to existing primary regulators to apply heightened standards and safeguards, and designating individual firms on a company-specific basis.”

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) granted FSOC such authorities under section 111, which established FSOC and its purposes, and section 113, which enumerated on its powers. Under section 113 of the Dodd-Frank Act, the FSOC can require nonbank financial companies to be supervised by the Federal Reserve and be subject to prudential standards if it determines that an entity poses a threat to the financial stability of the United States.

As further described in the articles below, such entities are designated as SIFIs, a label with growing implications under the current U.S. and global financial regulatory regime. FSOC’s conference on Monday highlights its increased interest in exploring risks posed by the asset management industry. Such an event is particularly important after a recent controversial report from the Office of Financial Research (see below) detailed potential systemic risks in the asset management industry. As Under Secretary Miller noted on Monday, “Our work to assess these risks is ongoing, and it will be based on a thorough analysis of information from a wide array of sources.”

 
 
STUDY FINDS LABELING ASSET MANAGERS SIFIs MAY CUT INVESTOR RETURNS BY 25 PERCENT
The American Action Forum (AAF) recently estimated that the cost of being labeled a systemically important financial institution (SIFI) by the Financial Stability Oversight Council (FSOC) could reduce investor returns by as much as 25 percent over the long-term. While the precise impact will depend on investors’ investment objectives, fund choice, and time horizon, AAF concludes that, in any context, new capital requirements will have noticeable effects on investors. A chart detailing the SIFI impact on specific asset management funds is included in the report.

To illustrate the general scale of the effect of SIFI designation, the report relies on the following assumptions: an 8 percent capital set-aside is applied; the FSOC designation applies only to funds with over $100 billion in assets; and total future returns (net of asset-weighted expense ratio) are equivalent to prior returns. The FSOC has used $100 billion as the threshold for an institution to qualify as a SIFI; there are currently 14 funds in the U.S. with assets exceeding that level. AAF notes that these conclusions reflect an upper bound on the cost that FSOC-prescribed capital requirements could have on investors, who have the option to switch between different funds to satisfy changing objectives and risk tolerance. Lower returns may simply encourage investors to switch into undesignated funds. Another major variable that will influence returns is the exact regulatory regime imposed on designated funds.

 
 
TREASURY IS ACCUSED OF IGNORING SEC FEEDBACK IN ASSET MANAGER STUDY
In a letter dated May 15, 2014, Securities and Exchange Commission (SEC) Commissioner Daniel Gallagher lambasts the controversial Asset Management and Financial Stability Study released by the Office of Financial Research (OFR) late last year. The study concludes certain activities in the asset management industry pose systemic risks, such as a reliance on short-term borrowing and the use of derivatives to boost returns. However, the report was quickly repudiated by the industry, Republican members of Congress, and even SEC Chair Mary Jo White, criticizing “the absence of empirical data underlying the generalizations advanced by the report and the flawed methodology used to analyze systemic risk,” according to Gallagher. Researchers at the Treasury Department are accused of ignoring feedback from the SEC, the sector’s primary regulator, to arrive at its conclusions.

Gallagher’s letter comes ahead of a conference on the asset management industry and its activities hosted by the Financial Stability Oversight Council (FSOC) on May 19th which was meant to further inform its work in that area. FSOC has been authorized under the Dodd-Frank Act to designate nonbank financial institutions “systemically important financial institutions” or SIFIs if their material financial distress or failure would pose risks to the financial stability of the U.S. Any company found to be a SIFI will be subject to consolidated supervision by the Federal Reserve and enhanced prudential standards. Three nonbank financial companies and eight financial market utilities have been designated SIFIs to date, but there is significant concern that FSOC will use the OFR report to establish a SIFI list for asset managers.

However, Gallagher argues that any representation in the report should be dismissed, claiming it inaccurately defines and describes the activities and participants in the asset management business, and “makes matters worse by analyzing the purported risks posed by asset managers in a vacuum instead of in the context of the broader financial markets,” among other fundamental flaws. Should the report serve as justification for designating asset managers systemically risky, it would be another example of “FSOC’s blatant and complete disregard for any input whatsoever from the primary regulator [such as] during the money market mutual funds debate.”

 
 
HOUSE FINANCIAL SERVICES EXAMINES THE FSOC’s TRANSPARENCY AND DESIGNATION PROCESS
On Tuesday, the House Financial Services Committee held a hearing to review the Financial Stability Oversight Council’s transparency into its process for designating companies as systemically important.

Last week, House Financial Services Committee Chairman Jeb Hensarling (R-TX), along with his five subcommittee chairmen, including Scott Garrett (R-NJ), sent a letter to members of the Financial Stability Board (FSB) and Financial Stability Oversight Council (FSOC) with their concerns about the FSB’s process for designating U.S. firms as Globally Systemically Important Financial Institutions (G-SIFIs).  “While we agree that robust communication between U.S. regulators and their overseas counterparts is important for global financial stability, we have concerns that decisions are being made that could have significant impact on the U.S. economy and its citizens through a nontransparent process, by an international body that is not accountable to the American people,” states the letter.

“The FSOC typically excludes members of the public, the media, Members of Congress, and regulators who are not FSOC Members from its meetings. In addition, the FSOC does not keep detailed minutes of its meetings,” stated the committee memo for the hearing.

To address these concerns, Scott Garrett introduced H.R. 4387, the FSOC Transparency and Accountability Act, which requires that the FSOC:

  • Hold open meetings;
  • Allow staff from the House Financial Services and Senate Banking, Housing, and Urban Affairs to attend and participate; and
  • Expands FSOC membership to include all members of the Board of the Federal Reserve, the Securities and Exchange Commission, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, the Commodity Futures Trading Commission and the National Credit Union Administration Board.
The committee will likely move forward with voting on H.R. 4387 in the near future
 
 
CHINA TO BEGIN ALLOWING ASSET SECURITIZATION
According to the Wall Street Journal (WSJ), Ford Automotive Finance (China) and Toyota Motor Finance (China) plan to securitize some of their auto loans in mainland China to better support increasing demand. Ford will sell nearly 800 million yuan ($128 million) worth of asset-backed securities (ABS) in China on Thursday, while Toyota will issue close to 800 million yuan worth of ABS next Friday, the two companies said separately. As stated in the article, China began allowing asset securitization on an experimental basis in 2005, but pulled back during the financial crisis. It restarted the program in 2012 and has gradually increased its size, with most of the ABS backed by banking loans. "As the world's second largest economy and the largest auto market, [Collateralized Loan Obligations] backed by corporate loans to large and small enterprises as well as auto ABS will continue to dominate China's fledging securitization industry," said Jian Hu, a Moody’s managing director.
 
 
OBAMA TO NAME JULIAN CASTRO TO HEAD DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
President Obama is expected to name San Antonio Mayor Julian Castro to lead the Department of Housing and Urban Development (HUD). The current HUD Secretary, Shaun Donovan, will likely be named to lead the White House office of Management and Budget.

Castro is widely seen as a rising star of the Democratic Party. He first took office as the youngest city council member to serve on the San Antonio City Council in 2001. He was first elected mayor of San Antonio in 2009 and is currently in his third two-year term leading the city. Castro also delivered the keynote address at the 2013 Democratic National Convention, and his nomination to fill the leadership position at HUD would add a Hispanic appointee to a cabinet that many view as under representative of a sizeable voting block.

The White House is expected to announce the nominations in the coming days.

 
 
CFTC IS EVALUATING OVERSEAS SWAP TRADING TO DETERMINE WHETHER BANKS ARE EVADING DODD-FRANK COMPLIANCE
The Commodity Futures Trading Commission (CFTC) will look at changes banks have made to their derivatives contracts or their corporate structures in order to free themselves from Dodd-Frank Act (Dodd-Frank) rulemakings. According to a recent Bloomberg report, Chairman Mark Wetjen acknowledged that such restructuring measures “could be perfectly legal,” but any evasive activity identified by the CFTC will be subject to rules against sidestepping the 2010 law. Any rules established under Dodd-Frank apply to trades in overseas affiliates that operate with the financial guarantee from their parent. However, non-guaranteed affiliates are subject to less scrutiny than overseas branches or guaranteed affiliates.

As a result, some U.S. banks have allegedly taken steps in recent months in order to trade with each other or with foreign-based banks that are not subject to Dodd-Frank rules. To do so, the largest swap dealers have allegedly been removing parent guarantees from affiliates or specific transactions so they can trade in the interdealer market without being subject to CFTC rules mandating price competition.

The Bloomberg report claims these measures are indicative of the latest effort by the financial services industry to curb the reach of CFTC rules that would have most credit default, interest rate, and other swaps traded on new platforms called swap-execution facilities. May 14th was the deadline for European swap-trading platforms to demonstrate they have sufficient competition between banks and other firms to remain exempt from direct U.S. oversight by the CFTC. CFTC has yet to announce any platforms that have applied for the relief.

 
 
CYBERSECURITY REMAINS AT TOP OF AGENDA FOR REGULATORS
Comptroller of the Currency, Thomas J. Curry, outlined what regulators are doing to meet the challenge of cyberattacks in a speech last week. He expressed his concerns over the country’s economic and national security and the risks that are posed by the growing sophistication and overall number of cyberattacks. Curry also highlighted the steady increase in malicious activity in the banking sector that allows criminals to steal credit card data and its substantial impact on consumers. In order to address these issues, Curry stated that national banks and federal savings associations, under the supervision of the Office of the Comptroller of the Currency (OCC), are devoting enormous amounts of time and resources to combat cyber threats. Regulators are keeping a closer eye on interconnected bank networks, specifically the extent to which service providers are consolidating and leaving more financial institutions dependent upon a single vendor and third-party access to sensitive consumer data.

Curry stated, “Recognizing the importance of managing third-party relationships, the OCC issued updated guidance last October that focuses on risk management practices for critical activities throughout the lifecycle of the third-party relationship. It also stresses the important role of the board of directors and management in overseeing these activities.”

Boards are expected to ensure that all risks are identified and understood, appropriate management practices are in place, clear accountability is established and that independent reviews are conducted periodically.

Curry highlighted the numerous briefings for banks, webinars, and support provided by the OCC to guide financial institutions through the supervisory process, as well as their utilization of the Federal Financial Institutions Examination Council, to raise awareness regarding cyber-threats and potential vulnerabilities. In closing, the Comptroller stated that “Sharing best practices, techniques and strategies, and collective responses to wide-scale events helps banks focus their resources on the most significant areas of concern. In an increasingly interconnected economy, information-sharing is vital, and not only for banks. The more we work together, the stronger and safer we all become.”

 
 
APPROPRIATIONS BILL PASSED WITH EMINENT DOMAIN LANGUAGE INCLUDED
This afternoon, the House Committee on Appropriations approved the fiscal year 2015 Transportation, Housing and Urban Development Appropriations bill by a vote of 28-21. As SFIG reported on May 7th, the bill included a provision that would prevent the Federal Housing Administration, Government National Mortgage Administration or Department of Housing and Urban Development from facilitating the use of eminent domain. As set forth in Section 233, those agencies shall not be permitted to use funds made available pursuant to the bill in order to, “insure, securitize, or establish a Federal guarantee of any mortgage or mortgage backed security that refinances or otherwise replaces a mortgage that has been subject to eminent domain condemnation or seizure, by a state, municipality, or any other political subdivision of a state.”

SFIG has consistently opposed the use of eminent domain to seize securitized mortgage loans for the purposes of modification. On August 30, 2013, SFIG filed an amicus curiae brief in support of a preliminary injunction against the City of Richmond, California and Mortgage Resolution Partners LLC (MRP), arguing that efforts by Richmond and MRP to seize loans held in securitized trusts is unconstitutional and could do permanent damage to the U.S. home mortgage system. SFIG also stated in the brief that eminent domain would “harm prospective homeowners across the country by imposing new, unanticipated and unquantifiable risks upon investors in mortgages, depressing the value of mortgage-based investments, and impeding the return of private capital to the residential mortgage market.”  These views were also expressed in SFIG’s Eminent Domain Position Paper and a recent Joint Trade Associations letter signed by SFIG supporting an amendment to the Johnson-Crapo bill from Senators Pat Toomey (R-PA) and Tom Coburn (R-OK) that would prohibit its use.

The bill will now move on to the full House for its approval.

GSEs INTRODUCE NEW RELIEF FROM BUYBACKS POLICY

Last week, Federal Housing Finance Agency (FHFA) Director Mel Watt stated FHFA was aware that mortgage repurchase risk was a priority for the industry and the issue was a focus in FHFA’s strategic plan for conservatorship. This week, at the direction of FHFA, Fannie Mae and Freddie Mac (collectively, GSEs) announced a new policy to curtail the number of repurchase requests to lenders.

 
 
UPCOMING EVENTS IN WASHINGTON
HEARING:  “ALLEGATIONS OF DISCRIMINATION AND RETALIATION WITHIN THE CONSUMER FINANCIAL PROTECTION BUREAU, PART TWO”
WEDNESDAY, May 21, 2014
10:00 a.m. (EST)
House Financial Services Subcommittee on Oversight and Investigations
2128 Rayburn House Office Building
A webcast of the hearing will be available on the House Financial Services Committee website.
 
 
FULL COMMITTEE MARKUP: “FY 2-14 TRANSPORTATION, HOUSING AND URBAN DEVELOPMENT APPROPRIATIONS BILL”
WEDNESDAY, MAY 21, 2014
10:00 a.m. (EST)
House Committee on Appropriations
2359 Rayburn House Office Building
A webcast of the hearing will be available on the House Appropriations Committee website.
 
 
HEARING:  “LEGISLATIVE PROPOSALS TO IMPROVE TRANSPARENCY AND ACCOUNTABILITY AT THE CFPB”
WEDNESDAY, May 21, 2014
2:00 p.m. (EST)
House Financial Services Subcommittee on Financial Institutions and Consumer Credit
2128 Rayburn House Office Building
A webcast of the hearing will be available on the House Financial Services Committee website.
 
 

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

Sonny Abbasi Director of MBS Policy

Sairah Burki Director of ABS Policy

Michael Flood Director of Advocacy

Mary Robinson Senior Policy Analyst

Alyssa Acevedo Policy Analyst

Amanda Bateman Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Executive Administration


1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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