May 25, 2016 Newsletter
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May 25, 2016
 
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
SPEAKERS AND AGENDA RELEASED FOR SFIG NEW YORK BLOCKCHAIN SYMPOSIUM

Following yesterday’s launch of the SFIG Blockchain Symposia Series, we are pleased to announce the agenda and panelists for our 2nd symposium, which will take place in New York on June 7, 2016.

Beginning with an introductory tutorial on “what is blockchain”, the panel will then discuss general applicability to capital markets, including reference to smart contracts and to the Delaware Blockchain Initiative – a comprehensive program to provide an enabling regulatory and legal environment for the development of blockchain technology. After the general discussion the panel will evaluate potential applications more specifically to the world of structured finance.

Panelists include:

  • Eamonn Maguire, Managing Director of Financial Management, KPMG
  • Marco Santori, Pillsbury Winthrop and State's legal advisor on the Delaware Blockchain Initiative
  • Mark Smith, CEO, Founder of Symbiont
  • Andrea Tinianow, Global Delaware Director and lead for the Delaware Blockchain Initiative
  • K. Waterman, Managing Partner and Chief Technology Officer, Ranieri Strategies

Moderator: Lewis Cohen, Partner, Hogan Lovells US LLP

Date: Tuesday, June 7th

Location:

Hogan Lovells US LLP
875 Third Avenue
25th floor
New York, NY 10022

Registration available here.

5:00pm Registration
5:30pm – Panel Discussion
6:30pm – Cocktail Reception

If you would like to be included in the newly created Blockchain Task Force, please email Alyssa.Acevedo@sfindustry.org. For questions regarding the symposium or other events, please email Sarah.Clarke@sfindustry.org.

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FINAL CALL – JOIN US IN TORONTO FOR STRUCTURED FINANCE CANADA 2016!

SFIG and IMN are anticipating record-breaking attendance at Structured Finance Canada 2016, taking place next week on May 31st and June 1st in Toronto. The event will commence the evening of May 31st, with an industry reception and dinner for conference delegates, providing an optimal setting to meet with current and prospective clients.

With close to 500 delegates registered – including more than 100 investors – this event will undoubtedly serve as the premiere annual industry meeting for all key structured finance participants in the Canadian marketplace. Investors, issuers and originators, dealers and traders, rating agencies and law firms, as well as Canadian regulators and policy makers will be participating.

We are also pleased to host the Honourable Charles Sousa, Minister of Finance, Legislative Assembly of Ontario, as the Keynote Speaker on Wednesday, June 1st. For more details on the conference agenda, please click here.

Conference Venue:
Hyatt Regency Toronto
370 King Street West
Toronto, Ontario, M5V 1J9
Canada

To register for Structured Finance Canada 2016, please click here.

We look forward to seeing you in Toronto next week!

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SFIG HOLDS CALL WITH SEC TO DISCUSS STUDENT LOAN ABS DISCLOSURE UNDER REGULATION AB II

Yesterday, May 24th, SFIG staff held a call with the U.S. Securities and Exchange Commission’s (“SEC”) Office of Structured Finance to discuss SFIG members' recommendations on student loan disclosure for both federal and private loans.

If you would like to join SFIG’s Regulation AB II Task Force, please contact 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 Analyst to Manager 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

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

For questions about positions at SFIG, please contact Jobs@sfindustry.org. For questions about the website jobs portal, please contact Website@sfindustry.org.

Current members are encouraged to advertise open positions within their company on SFIG's website by filling out the form here.

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SFIG CALENDAR
MEETINGS
BIWEEKLY RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, May 31, 2016
11:00 a.m. – 12:00 p.m. (ET)

 
 
MONTHLY CHINESE MARKET COMMITTEE CALL

WEDNESDAY, June 1, 2016
9:00 a.m. – 10:00 a.m. (ET)

 
 
WEEKLY CREDIT CARD ISSUER COMMITTEE CALLS

THURSDAY, June 2, 2016
10:00 a.m. – 11:00 a.m. (ET)

 
 
BLOCKCHAIN TASK FORCE KICK-OFF CALL

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

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EVENTS
SFIG WiS EVENT IN TORONTO

TUESDAY, May 31, 2016
3:00 p.m. – 5:00 p.m. (ET)
McCarthy Tétrault LLP
Toronto, Ontario
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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SFIG NYC SYMPOSIUM ON BLOCKCHAIN TECHNOLOGY

TUESDAY, June 7, 2016
5:00 p.m. – 7:00 p.m. (ET)
Hogan Lovells US LLP
875 Third Avenue
New York, NY 10022
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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SFIG BOARD OF DIRECTORS MEETING

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

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IMN’s ABS EAST 2016 CONFERENCE

SUNDAY, September 18, 2016 – TUESDAY, September 20, 2016
The Fontainebleau
Miami Beach, FL
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
MASSACHUSETTS DELEGATION URGES FHFA TO DELAY IMPLEMENTATION OF NEW SUPER LIEN POLICY

Last Monday, May 16th, Senator Elizabeth Warren (D-MA) published a letter on her website from the Massachusetts congressional delegation to Federal Housing Finance Agency (“FHFA”) Director Mel Watt urging him to delay implementation of FHFA’s new policy on state super lien laws until the public has had a chance to comment on the issue. As stated in the letter, “Given the widespread effect that FHFA's new policy will have, we believe the agency should solicit and consider public comments before implementing it. Accordingly, we request that FHFA delay implementation of its new policy on state super lien laws and set up a process for obtaining and reviewing public comments on the issue. FHFA should consider how its policy would advance each of its statutory purposes, including its obligation to ensure that ‘the operations and activities of each regulated entity foster liquid, efficient, competitive, and resilient national housing finance markets.'"

Massachusetts, along with 21 other states and the District of Columbia, have super lien laws that give homeowners associations liens priority over first mortgage liens which allows homeowners associations to foreclose on a property to collect the priority portion of their lien. This usually consists of up to six months’ worth of owed fees. FHFA announced a policy last year under which it will not consent to the foreclosure of Fannie Mae or Freddie Mac liens in connection with these super lien laws. SFIG has actively engaged Congress in the super lien issue and urged a balanced solution under which homeowners are notified before foreclosure proceedings are initiated, thereby providing them with an opportunity to pay the homeowners association fees first. For questions about SFIG’s advocacy on this matter, please contact Thomas.Mccrocklin@sfindustry.org or Daniel.Goodwin@sfindustry.org. To join SFIG’s GSE Reform Task Force and learn more, please contact Amanda.Bateman@sfindustry.org.

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SoFi SECURITIZATION RATED AAA FROM MOODY’S, A FIRST IN MARKETPLACE LENDING

While the marketplace lending industry has taken some hits this year, the Wall Street Journal is reporting that one online lender has secured a triple-A rating from Moody’s on its recent securitization. According to the article, Social Finance Inc., known as "SoFi", received the first triple-A rating from Moody’s – the first ever for a marketplace lender. The $380 million offering is backed by student loans originated online.

As the Wall Street Journal reports, the deal “featured 38 investors, including from Europe and Asia, with about a third of them new investors”, according to SoFi Chief Financial Officer Nino Fanlo. In another first, SoFi “kept the riskiest part of the deal,” Fanlo said, meaning that SoFi  “is exposed to losses” if the deal performs poorly.

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EU’s ABS REVIVAL PROGRAM SHOULD INCLUDE TRANSPARENCY, ACCORDING TO PARLIAMENT MEMBER

Last Thursday, European Parliament member Paul Tang introduced a report calling for transparency in the E.U.’s ABS market. The E.U.’s plan to revive this market must contain “crystal-clear” disclosure rules to prevent investors from taking on excessive risk, according to a recent Bloomberg article.

In the report, Tang proposes a public register for “essential information of securitizations and which investor holds which position,” providing an “important safeguard whenever the market would come under stress in the future.” Additionally, in order to gain the benefits of securitization, “important lessons from the financial crisis have to be learnt, important lessons concerning asymmetry of information and moral hazard,” Tang wrote. “These problems will not be solved by the market on itself and need to be dealt with in the [simple, transparent, and standardized] STS framework.”

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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

Dan Goodwin Director, Mortgage Policy

Tom McCrocklin Director, Advocacy

Jennifer Wolfe Manager, ABS Policy

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Senior Analyst, MBS Policy

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

Dani Hernandez Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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