November 19, 2014 Newsletter

SFIG News

SFIG Calendar

Advocacy Outlook

Industry News Highlights

Upcoming Events in Washington

 
SFIG NEWS
SFIG LEADERSHIP MEETS WITH IOSCO ON GLOBAL SECURITIZATION AGENDA

On November 10th, SFIG Chairman Reggie Imamura and Executive Director Richard Johns, met with International Organization of Securities Commissions ("IOSCO") Chairman Greg Medcraft and staff in Sydney, Australia. The meeting provided SFIG with an opportunity to follow up with IOSCO on a number of key topics that were discussed during a roundtable held over the summer in London, including the development of sustainable securitization markets as a source of funding for the real economy and the transformation of shadow banking into resilient market-based finance. SFIG expressed support for IOSCO's efforts to promote "simple, transparent and comparable" securitizations as a funding tool and highlighted its own efforts to revitalize the private label mortgage backed securities market through the development of such standards under Project RMBS 3.0. SFIG also highlighted the launch of its High Quality Securitization Task Force during its meeting with IOSCO.

 
 
SFIG & IMN HOLD HISTORIC PRIVATE LABEL RMBS REFORM SYMPOSIUM

Last week, SFIG and IMN co-hosted their first Private Label RMBS Reform Symposium to great success and positive response from the industry. Over 500 industry participants registered for the event, and SFIG was pleased with the candid and open discussion amongst all in attendance.

The symposium featured morning panels and Dr. Michael Stegman, Counselor to the Secretary of the Treasury for Housing Finance Policy, as keynote speaker. Much of Dr. Stegman’s address referenced Treasury’s own opinions, those gleaned from Treasury’s discussions with individual market participants, and roundtables that focused on the current benchmark transaction that Treasury is engaging the market in developing. Dr. Stegman stated that Treasury did not believe trustees should have a fiduciary role, but it did believe an independent reviewer function was something necessary to provide both servicer oversight and to review loans for breaches of representations and warranties.

The afternoon sessions were a series of roundtable/audience participation panels targeted specifically towards the creation of a sustainable private label securities market through meaningful and productive industry engagement.

Issues arising through SFIG’s RMBS 3.0 initiative appeared throughout the day’s panels and discussions. As RMBS 3.0 moves beyond the Second Edition Green Papers and forward with its agenda, key areas of importance raised by symposium attendees and RMBS 3.0 participants are the highest priority for the initiative to tackle next.

Key themes of the day included:

  • principal reduction modifications specifically regarding regulatory or judicial settlements and their impact to investor cash-flows and losses;
  • alignment of interests between transaction parties;
  • the consideration of fiduciary duty and the potential parties that could absorb both roles and duties, most notably the concept of a collateral or transaction manager; and
  • key issues relating to reps and warranties, including the concept of sunsets.

A full agenda is available on IMN’s website, including recordings of selected panels.  SFIG will make edited transcripts available to members of its RMBS 3.0 committee at a later date. 

For additional information on Project RMBS 3.0, or to join the Task Force, please contact Mary.Robinson@sfindustry.org.
 
 
SFIG KICKS OFF INDUSTRY GUIDE WORK-STREAM CALLS

Yesterday, SFIG launched two of its industry guide calls focusing on the establishment of consensus positions and best practices for critical elements of the new Regulation AB II and Risk Retention final rules.

Tomorrow, SFIG will hold the third of its inaugural industry guide calls, this one focusing on Nationally Recognized Statistical Rating Organizations (“NRSROs”) Due Diligence at 4:30 p.m. (EST). If you are interested in joining this work-stream, please contact Amanda.Bateman@sfindustry.org.

If you are interested in joining either the Regulation AB II or Risk Retention industry guide work-stream, please contact Alyssa.Acevedo@sfindustry.org.

 
 
SFIG will not release a newsletter next week on account of the holiday.  We wish you all a safe and happy Thanksgiving.
 
 
SFIG CALENDAR
CREDIT CARD ISSUER REGULAR BIWEEKLY CALL RE: REG AB II

THURSDAY, November 20, 2014
10:00 a.m. – 11:00 a.m. (EST)

 
 
RESIDENTIAL MORTGAGE COMMITTEE REGULAR BIWEEKLY CALL RE: REG AB II

THURSDAY, November 20, 2014
2:00 p.m. – 3:00 p.m. (EST)

 
 
NRSRO INDUSTRY GUIDE CONFERENCE CALL

THURSDAY, November 20, 2014
4:30 p.m. – 5:30 p.m. (EST)

 
 
ANDREW DAVIDSON & CO., INC.’S HOUSING FINANCE BEFORE AND AFTER THE CRISIS: ANALYTICAL CONCLUSIONS THAT IMPACT PUBLIC POLICY

THURSDAY, November 20, 2014
5:00 p.m. – 8:00 p.m. (EST)
National Press Club
529 14th Street NW
Washington, DC
Registration is available here.

Richard Johns will be speaking to important questions affecting housing finance reform.

 
 
14th BANKING AND FINANCE FORUM

FRIDAY, November 21, 2014
9:00 a.m. – 4:00 p.m. (EST)
The Ritz-Carlton Hotel
201 East Trade Street
Charlotte, North Carolina

Mike Flood will be speaking on the “Recent Legislative Developments in Banking & Finance Law” panel.

 
 
AMERICAN BAR ASSOCIATION BUSINESS LAW SECTION FALL MEETING

November 21-22, 2014
The Ritz-Carlton Hotel
1150 22nd Street NW
Washington, DC

Sairah Burki will be speaking on the “Securitization Regulation: New Developments” panel on Friday, November 21st at 8:00 a.m. (EST).

 
 
HIGH QUALITY SECURITIZATION TASK FORCE WEEKLY CALL

TUESDAY, November 25, 2014
10:00 a.m. – 11:00 a.m. (EST)

 
 
HIGH QUALITY SECURITIZATION TASK FORCE WEEKLY CALL

TUESDAY, December 2, 2014
10:00 a.m. – 11:00 a.m. (EST)

 
 
BIWEEKLY RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, December 2, 2014
11:00 a.m. – 12:00 p.m. (EST)

 
 
SFIG MEETING WITH FHFA REGARDING SINGLE SECURITY

WEDNESDAY, December 3, 2014
11:00 a.m. (EST)
Note: Closed Meeting

 
 
BIWEEKLY REGULATION AB II INDUSTRY GUIDE CALL

WEDNESDAY, December 3, 2014
3:00 p.m. – 4:00 p.m. (EST)

 
 
PLI SEMINAR: NEW DEVELOPMENTS IN SECURITIZATION 2014

THURSDAY, December 4, 2014
9:00 a.m. – 5:00 p.m. (EST)
PLI New York Center
1777 Avenue of the Americas
New York City, NY

Richard Johns will be speaking on the “Examining Key Regulations Through a Global Lens” panel.

 
 
HIGH QUALITY SECURITIZATION TASK FORCE WEEKLY CALL

TUESDAY, December 9, 2014
10:00 a.m. – 11:00 a.m. (EST)

 
 
SFIG BOARD OF DIRECTORS MEETING

WEDNESDAY, December 10, 2014
12:00 p.m. – 5:00 p.m. (EST)
Dentons
1221 Avenue of the Americas
New York, NY
Note: Closed Meeting

 
 
HIGH QUALITY SECURITIZATION TASK FORCE WEEKLY CALL

TUESDAY, December 16, 2014
10:00 a.m. – 11:00 a.m. (EST)

 
 
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.

The RMBS 3.0 Task Force released its Second Edition RMBS 3.0 Green Paper. Following the successful SFIG/IMN Private Label RMBS Symposium, the Task Force will continue its efforts to address key issues specific to private label mortgage securities through work streams relating to (1) Representations, Warranties, and Repurchase Enforcement; (2) Due Diligence, Data, and Loan-Level Disclosure; and (3) Role of Transaction Parties and Bondholder Communications. We encourage members to participate in any or all of the working groups to contribute towards the mission of RMBS 3.0. For additional information on RMBS 3.0, or to join the Task Force, please contact Mary.Robinson@sfindustry.org.

The GSE Reform Task Force has been actively engaging the Federal Housing Finance Agency in recent months, including SFIG’s October 13th response to the proposed structure for a single agency security. SFIG has also recently submitted comments on guarantee fee pricing and FHFA’s Strategic Plan for 2015-2019. The Task Force previously reviewed various proposals in Congress including the Johnson-Crapo bill, with SFIG staff summarizing members’ recommendations in a briefing book, and the PATH Act. If you would like to learn more about SFIG’s activities in these areas, 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 in February of this year. SFIG also continues to have weekly Mortgage Industry Standards Maintenance Organization calls to go through data elements that lenders should deliver in securitizations. We will also be conducting an analysis of the data elements included in SFIG’s Schedule L submission in order to determine any privacy concerns. Please contact Alyssa.Acevedo@sfindustry.org for additional information on SFIG’s work on this topic.

The Volcker Task Force has been working with SFIG’s various asset class and legal counsel committees to identify areas within the Volcker Rule in need of clarification, particularly questions regarding covered funds and the loan securitization exemption. Please contact Amanda.Bateman@sfindustry.org to participate on the Volcker Task Force.

The Risk Retention Committee met on October 27th to discuss the newly released Credit Risk Retention final rule. SFIG also held its first biweekly industry guide work-stream call yesterday regarding the implementation of the final rule. Please contact Alyssa.Acevedo@sfindustry.org with any questions.

SFIG’s Chinese Market Committee continues to hold regular calls focusing on a high-level description of SFIG’s partnership with the Chinese Securitization Forum, potential upcoming educational discussions and a sharing of recent market developments in China. If you would like more information on SFIG’s work with respect to Chinese securitization, please contact Alyssa.Acevedo@sfindustry.org.

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

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

The Task Force will have its first full meeting in the coming weeks, and members from across asset classes are encouraged to participate. To register your interest in SFIG’s Shadow Banking Initiative, please contact Amanda.Bateman@sfindustry.org.

The Regulation AB II Task Force will focus on the disclosure and offering process requirements within the final rule. Two work-streams have been formed to develop a comment letter on the proposed rules that remain outstanding and to produce an industry guide for critical elements of the final rule. Monthly task force calls will be held to identify and address key questions regarding the implementation of the final rule. We will also be holding bi-weekly calls for the asset-level committees. SFIG members who are interested in joining this task force or asset specific committees should contact Alyssa.Acevedo@sfindustry.org.

The Regulatory Capital and Liquidity Committee is addressing industry concerns related to the Federal Reserve Board’s Final Rule on the Liquidity Coverage Ratio (“LCR”). This committee will also review the BCBS final standard for the Net Stable Funding Ratio (“NSFR”) and to develop a comment letter when U.S. regulators release their proposed NSFR. To become involved in SFIG’s advocacy on the Final LCR rule or NSFR, please contact Alyssa.Acevedo@sfindustry.org.

The Derivatives in Securitization Task Force will be commenting on the CFTC’s proposal on margin requirements for uncleared swaps as well as the prudential regulators’ proposal regarding margin and capital requirements for covered swap entities. SFIG submitted a comment letter at the end of June, advocating for asset-backed securities issuers to qualify for the “low-risk financial end user” designation proposed by prudential regulators in the original proposal. SFIG members who are interested in learning more about this initiative should email Amanda.Bateman@sfindustry.org.

The Credit Rating Reform Task Force has been discussing the SEC’s recent Final Rules with respect to Nationally Recognized Statistical Rating Organizations (“NRSROs”) and third party due diligence services for transactions involving registered and private asset-backed securities with assigned credit ratings. SFIG is developing an industry guide for the due diligence elements of the final rule on NRSROs. Those interested in learning more should contact Amanda.Bateman@sfindustry.org.

The Money Market Fund Reform Working Group submitted a comment letter on October 13th regarding the Securities and Exchange Commission’s July 23rd proposal which includes, among other things, possibly amending rule 2a-7’s issuer diversification provisions to eliminate an exclusion that is currently available for securities subject to a guarantee issued by a non-controlled person. SFIG also submitted a comment letter in September 2013 on Money Market Fund Reform. If you are interested in joining this working group, please contact Alyssa.Acevedo@sfindustry.org.

The High Quality Securitization (“HQS”) Task Force will serve as the forum through which SFIG will respond to recent initiatives that seek to define “qualifying securitizations,” such as the European Banking Authority’s Discussion Paper on simple standard and transparent securitization. The task force will meet every Tuesday at 10:00 a.m. (EST) until the letter’s submission on January 14th. If you are interested in joining the HQS Task Force, please email Amanda.Bateman@sfindustry.org.

 
 
INDUSTRY NEWS HIGHLIGHTS
FSB REPORTS ON PROGRESS OF GLOBAL FINANCIAL REFORM AT G20 SUMMIT IN BRISBANE

During the G20 summit in Brisbane, Australia this weekend, the Financial Stability Board (“FSB”) provided its leaders with the opportunity to hear from top officials from global and national standard-setting bodies on the progress of their financial reform program. FSB Chairman Mark Carney surmised the progress made thus far and highlighted the major areas still requiring attention in a letter to the G20 entitled, “Financial Reforms: Completing the Job and Looking Ahead.” According to Mr. Carney, measures to fix the fault lines that caused the crisis have largely been agreed to and regulators or officials are “building more resilient financial institutions and robust markets.” With respect to ending “too big to fail,” Carney said that an endorsement by the G20 leaders would be a “watershed” which, once implemented, will play an important role in enabling the resolution of systemically important banks without leaving the taxpayer on the hook or the broader financial system in turmoil.

During the next phase of financial reform, Carney said that FSB would be focused on addressing new and emerging risks, with a particular emphasis on those arising outside the core banking system. Finally, Carney encouraged the G20 leaders to support the FSB’s efforts to build trust and cooperation in the financial system through the implementation of common standards, the recognition of differences which need to be considered by national regulators implementing the minimum standards, and the deferral to the regulatory regimes of others so that inefficient duplications and conflicting regulation can be prevented. Reports on the FSB’s review of the structure of its representation and the overall progress of the G20’s financial reform program were included as support for the letter.
 
 
CHINESE BANKS PLAN ISSUANCE OF SHARES TO MEET BASEL STANDARDS

Three of China’s top banks will be issuing up to 60 billion yuan ($9.7 billion) of preference shares by the end of the year, according to a recent Reuters article and filings with the Shanghai Stock Exchange. Preference shares behave like bonds and convert into common equity if a bank's core capital falls below certain trigger ratios. They were first introduced and welcomed by Chinese investors in 2013 because they are considered non-dilutive to ordinary share valuations.

Shanghai Pudong Development Bank Co. Ltd, the Industrial Bank Co Ltd and the Bank of China Ltd plan to issue 15 billion yuan ($2.4 billion), 13 billion yuan ($2.1 billion) and 32 billion yuan ($5.2 billion) of preference shares, respectively. These banks are hurrying to replenish their balance sheets to meet the new Basel III global bank capital regulations.

As previously reported by SFIG, the Bank of China’s contingent capital deal of 39.8 billion yuan ($6.5 billion) last month was the world’s largest ever and first effort to strengthen its balance sheets.

 
 
ECB PURCHASE PLAN LIFTING ABS PRICES

The price for buying asset-backed securities (“ABS”) has begun to rise, in anticipation of the European Central Bank (“ECB”) beginning its ABS purchase program next week, according to a report by the Financial Times.  The ECB hopes buying ABS will help fuel lending to the European Union’s (“EU”) smaller businesses and, over the long-term, reduce reliance on EU banks by creating a bigger capital market for companies to tap.  “Prices have shot up as spreads of ABS presumed eligible for the ECB purchase programme have moved in by as much as 40 basis points in the periphery since the programme was first announced in September,” said Alex Batchvarov, managing director at Bank of America Merrill Lynch.  It comes as annual European ABS volumes are poised to fall to fresh post-financial crisis lows.  

Under the program, the ECB will purchase only the safest “senior” parts of the ABS structure, which has helped push spreads to fresh lows.  “It [the ECB] is artificially suppressing spreads,” said James King, an ABS portfolio manager at M&G. “As long as the ECB is buying, spreads stay [low] but they haven’t transformed appetite – as soon as it stops there’s nothing to keep those spreads where they are. “The fundamental question is: who is the end buyer for ABS in Europe?”

Critics contend that, if it hopes to unblock lending pipes, the ECB will also need to buy riskier “mezzanine” ABS tranches to give banks capital relief from regulators.

“The success of the ECB’s plan will be predicated on new [ABS] issuance – that will mainly happen if the banks have capital benefits and that depends on whether and at what price the banks can place mezzanine [tranches],” said Mr. Batchvarov. So far proposals to buy “guaranteed” mezzanine tranches have faced opposition from countries including Germany and France.

 
 
IO TREND IN CMBS RAISES CONCERNS

According to a Globe Street report, CMBS analysts have recently observed increasing loan-to-value ratios and a rise in interest-only (“IO”) loans since 2009.  A recent Moody’s Investors Service report found that about two-thirds of the CMBS deals originated in the third quarter were IO, compared to 50 percent of the loans originated during 2013. Similarly, Fitch Ratings found that combining IO and partial-IO represent nearly 60 percent of the conduit loans issued through Q3 2014, up from a total of 33.1 percent at the end of 2012.

An article in the Fitch Ratings weekly CMBS newsletter summed up its conclusions: “Interest-only loans demonstrated noticeably higher default, severity and loss rates than amortizing loans. This relationship held true even when controlled for vintages. If the 2006-2008 vintages are removed, interest-only loans still underperformed amortizing loans.”  The large upcoming wave of $300 billion in CMBS maturities could see more IO defaults from the 2006-08 vintages.  Fitch also found that partial-IO loans were the quickest to default at 56 months after origination on average, suggesting that the change in payment terms may cause some borrowers to default earlier in the term of the loan. Of the partial-IO loans that defaulted, approximately 27 percent did so before the end of their initial IO period, while the remaining 73 percent defaulted an average of 28 months after switching from IO to amortizing.  Fitch based its study on 47,443 conduit loans originated between ’94 and ’08 and totaling $414.5 billion in original securitized principal balance, and examined performance metrics through the end of last year.
 
 
HUD SECRETARY STATES HOUSING FINANCE REFORM REMAINS TOP PRIORITY FOR THE OBAMA ADMINISTRATION

On Monday, Housing and Urban Development (“HUD”) Secretary Julian Castro stated that overhauling the mortgage finance system remains a top priority for the final two years of the Obama administration in an interview with Bloomberg TV.

Castro suggested that the next Congress should consider legislation winding down Freddie Mac and Fannie Mae as part of an effort to boost the housing market’s recovery. The Secretary also pointed to bipartisan pieces of legislation like Johnson-Crapo and Corker-Warner, stating that, "This could be, I believe, a good victory either in the lame-duck session or, more realistically, perhaps in the next term of Congress where there is bipartisan support for housing finance reform.”

He ended by adding that a priority of the HUD administration is introducing “more private capital into the market and taking the taxpayers off the hook if we ever do experience what we just went through as part of the housing crisis in 2007, 2008, 2009.”

 
 
SENATORS WARREN AND WARNER URGE FHFA ACTION ON HOUSING FINANCE INFRASTRUCTURE AND ACCESS TO CREDIT

Yesterday, Senator Elizabeth Warren (D-MA) and Senator Mark Warner (D-VA) wrote a letter to Federal Housing Finance (“FHFA”) Director Melvin Watt and highlighted six areas where the FHFA can improve and bring transparency to the housing finance infrastructure it is attempting to build:

  1. Developing a single security for Fannie Mae and Freddie mortgage-backed securities (“MBS”), while soliciting additional input from industry participants, including an industry advisory board,
  2. Developing a common securitization platform (“CSP”) with transparency into the progress and timeline to complete the project,
  3. Expanding risk-sharing programs to encourage the private sector to take on a growing amount of credit risk in the agency MBS market,
  4. Creating specific uniform public regulations for private mortgage insurers that insure loans guaranteed by Fannie Mae and Freddie Mac,
  5. Expanding and improving the First Look Program for owner-occupants to purchase homes, and
  6. Updating the credit scoring models that Fannie Mae and Freddie Mac use
“While we work in Congress to pass comprehensive housing finance reform, we are asking FHFA to move responsibly and transparently as they lay the foundation for a system that better protects taxpayers and improves access to credit for homeowners,” stated Senator Warner.
 
 
FHFA DIRECTOR WATT TESTIFIES BEFORE SENATE ON GSES

Today, Director of the Federal Housing Finance Agency (“FHFA”) Melvin Watt testified before the US Senate Committee on Banking, Housing and Urban Affairs regarding the status of Fannie Mae and Freddie Mac (collectively, the “GSEs”).  In his prepared remarks, Director Watt highlighted the following key points of note to SFIG members:

  • Since the establishment of the conservatorships in 2008, the financial performance of the GSEs has improved significantly;
  • FHFA is continuing the process of updating and clarifying the representation and warranty framework for the GSEs;
  • GSEs will provide targeted access to credit opportunities for creditworthy borrowers who have compensating factors and risk mitigants;
  • GSEs have made significant progress on the design-and-build phase of the common securitization platform and the GSEs will work to ensure a smooth transition to the CSP;
  • FHFA is continuing to assess single security and is reviewing input received from market participants; and
  • FHFA is also continuing to assess the issue of guarantee fees. 

In response to questions from Senators regarding principal reductions for borrowers, Director Watt responded that FHFA was continuing to assess the issue.

 
 
FHA RELEASES REPORT ON MUTUAL MORTGAGE INSURANCE FUND

On Monday, the Federal Housing Administration (“FHA”) released is annual report to Congress regarding the Financial Status of the FHA Mutual Mortgage Insurance (“MMI”) Fund for single-family programs. According to a HousingWire article, this report shows the financial health of the regulating agency improved dramatically, but still needs some improvements in terms of its finances.

During the past 12 months, the MMI Fund, which handles single-family programs, gained nearly $6 billion in value and is now “positive and on a strong trajectory.” Last year, it fell short by more than $1.3 billion. Overall, the FHA boasted a $21 billion improvement since late 2012 and after implementing a series of financing changes. Delinquency rates also dropped by 14 percent and recovery rates improved by 16 percent since last year.

“This year’s report shows that the fundamentals of the fund are strong,” said Housing and Urban Development Secretary Julian Castro in a statement that accompanied the report. "Over the past five years, FHA has taken a number of prudent actions to restore the fund’s fiscal health. This is positive news for the economy and the millions of American families that count on FHA."

In terms of areas of improvement needed, the MMI capital ratio still stands well below the optimal 2 percent capital reserve at 0.41 percent. The FHA stated that it “will continue to execute on the policies that have supported both the turnaround in the Fund and an appropriate expansion of credit access to the underserved.”
 
 
UPCOMING EVENTS IN WASHINGTON
SEC MEETING: GOVERNMENT-BUSINESS FORUM ON SMALL BUSINESS CAPITAL FORMATION

THURSDAY, November 20, 2014
10:00 a.m. (EST)
SEC Headquarters, 100 F Street NE, Washington, DC

 
 
SENATE FINANCIAL INSTITUTIONS AND CONSUMER PROTECTION SUBCOMMITTEE HEARING – “IMPROVING FINANCIAL INSTITUTION SUPERVISION:  EXAMINING AND ADDRESSING REGULATORY CAPTURE”

Friday, November 21, 2014
10:00 am (EST)
538 Dirksen Senate Office Building
Washington, DC 20515
A webcast of the hearing will be available here.

 
 

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 Policy Manager

Alyssa Acevedo Policy Analyst

Amanda Bateman Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Executive Administration


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Washington, DC 20006

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