November 4, 2015 Newsletter
To ensure receipt of this newsletter, please add info@sfindustry.org to your address book. 
Problem viewing this email? Click here for our online version.
November 4, 2015
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
SFIG SUBMITS RESPONSE TO MOODY’S ON PROPOSED CHANGES TO RATING METHODOLOGY FOR FFELP STUDENT LOAN ABS

Last Friday, October 30th, SFIG’s Student Loan Committee submitted a response to Moody’s Investor Service’s Request for Comment regarding proposed changes to its rating methodology for securities backed by Federal Family Education Loan Program (“FFELP”) student loans.

If you would like to join SFIG’s Student Loan Committee, please contact Alyssa.Acevedo@sfindustry.org

 
 
SFIG TO SUPPORT EXPECTED SUPREME COURT PETITION IN MADDEN V. MIDLAND CASE

SFIG has engaged Sidley Austin LLP to file an amicus curiae brief in support of an expected Midland Funding LLC petition with the Supreme Court requesting judicial review of Second Circuit Court of Appeals’ decision in Madden v. Midland Funding.

Midland’s request for a rehearing by the Second Circuit that SFIG, along with the Securities Industry and Financial Markets Association, supported was denied.

The outcome of Madden v. Midland has far-reaching implications for the securitization of consumer loans, especially those funded through marketplace lending channels. If the Second Circuit’s decision is upheld, then industry participants would need to evaluate the applicability of state usury laws for loans included in a securitization.

To learn more about SFIG’s amicus curiae review process, please contact Alyssa.Acevedo@sfindustry.org.

 
 
SFIG's WiS NETWORKING WORKSHOP

Save the date! WiS invites industry women to learn how to most effectively and enjoyably expand their network with an exciting workshop, followed by a networking reception. Space is limited and priority registration will be provided to registered WiS members. If you are not yet registered with WiS, sign up here

DATE: Tuesday, December 8, 2015
TIME: 4:00-7:00 p.m. (ET)
LOCATION:  New York, NY

A reception will follow this event. Please note that while the initiative is open to all industry members, attendance at the event is limited to industry women. Additional details and registration are forthcoming.

 
 
SFIG & IMN’s ABS VEGAS 2016 AGENDA AND SPEAKER NOMINATION NOW AVAILABLE!

SFIG and IMN are proud to announce the agenda for ABS Vegas 2016! In keeping with SFIG’s dedication to inclusion and respectful accommodation of divergent member views, this program is the result of a collaborative effort between IMN and SFIG’s Conference Committee. 

SFIG members may complete the online form to nominate a speaker for the ABS Vegas 2016 by clicking the link here. You must be logged in to access the member-only form. If you do not have an account, you can create one here. Non-members of SFIG may submit their nominations by clicking here.

Submissions are due no later than November 20, 2015. If you have difficulty accessing the nomination form or have any questions about the conference, please email Events@SFIndustry.org.

Sponsorship of this event is not a guarantee of speaker placement. Priority consideration is given to current SFIG members who are actively engaged in the industry, and speaker placement will be determined by the SFIG Conference Committee. SFIG members may self-nominate, or submit on behalf of a non-member.

SFIG members receive special discounted rates off registration and sponsorship. Click here to reserve your place today.

Sponsorship opportunities are also available. For sponsorship opportunities, please contact Christopher Keeping at 212-901-0533 or ckeeping@imn.org.

 
 
DELAYED NEWSLETTER DISTRIBUTION NEXT WEEK
Please note that next week’s SFIG newsletter distribution will be delayed until Thursday, November 12th due to Veteran’s Day.
 
 
INDUSTRY JOBS

SFIG currently has a position open for:

  • Communications and Media Manager: will be an integral member of SFIG staff, providing support across the whole organization and serving as a vital link between SFIG, its membership and other external audiences. Additional information on the position, as well as a link to the application, is available here.

Some of the latest industry positions available include:

JOB TITLE   COMPANY POSTING DATE
Associate Analyst 2   Moody’s Corporation 11-02-15
Senior Vice President, RMBS Monitoring   Moody’s Corporation 11-02-15
Vice President, Senior Credit Officer   Moody’s Corporation 11-02-15
CLO Legal Analyst   Moody’s Corporation 11-02-15
AVP - Analyst   Moody’s Corporation 11-02-15
Lead Ratings Analyst – Asset Backed Securities Group (Student Loans)   Moody’s Corporation 11-02-15
Analyst [4417BR]   Moody’s Corporation 11-02-15
Senior Vice President Operational Risk Assessment Analyst   Morningstar Credit Ratings, LLC 10-29-15
High Yield - Legal Analyst   Babson Capital Management 10-22-15
Finance Associate   Hogan Lovells US LLP 10-09-15

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.

 
 
SFIG CALENDAR
MEETINGS
INVESTOR COMMITTEE CALL ON RMBS 3.0

THURSDAY, November 5, 2015
9:00 a.m. – 10:00 a.m. (ET)

 
 
RMBS 3.0 REPRESENTATIONS AND WARRANTIES CALL

THURSDAY, November 5, 2015
5:00 p.m. – 6:00 p.m. (ET)

 
 
WEEKLY CREDIT CARD ISSUER COMMITTEE CALLS
  • THURSDAY, November 5, 2015
    10:00 a.m. -11:00 a.m. (ET)
  • THURSDAY, November 12, 2015
    10:00 a.m. -11:00 a.m. (ET)
 
 
BIWEEKLY RISK RETENTION INDUSTRY GUIDE CALL

TUESDAY, November 10, 2015
11:00 a.m. – 12:00 p.m. (ET)

 
 
BIWEEKLY AUTO ISSUER COMMITTEE CALL

TUESDAY, November 10, 2015
2:00 p.m. – 3:00 p.m. (ET)

 
 
RESCHEDULED EQUIPMENT ISSUER COMMITTEE CALL

TUESDAY, November 10, 2015
3:00 p.m. – 4:00 p.m. (ET)

 
 
EVENTS
SFIG & IMN’s PRIVATE LABEL RMBS REFORM SYMPOSIUM

THURSDAY, November 12, 2015
Marriott New York Downtown
New York, NY

  • Richard Johns will deliver the opening remarks and speaking on the “RMBS Instant Replay” panel
  • Dan Goodwin will moderate the “State of the Non-Agency Market” panel
  • Mary Robinson will moderate the “Proposed Deal Manager/Agent Frameworks” panel
  • Michael Flood will moderate the “Credit Risk Transfer Program: Impact on PLS RMBS” panel

Registration is available here. The agenda can be found here.

 
 
MCB CONTINUING LEGAL EDUCATION 15th BANKING AND FINANCE FORUM

FRIDAY, November 20, 2015
9:00 a.m. – 4: 00 p.m. (ET)
Charlotte, NC

  • Michael Flood will speak on the “Legislative Developments in Banking” panel
 
 
SFIG WiS PROFESSIONAL NETWORKING WORKSHOP
TUESDAY, December 8, 2015
4:00 -7:00 p.m. (ET)
New York, NY
A reception will follow this event. Please note that while the initiative is open to all industry members, attendance at the event is limited to industry women. Additional details and registration are forthcoming.
 
 
SFIG BOARD OF DIRECTORS MEETING

WEDNESDAY, December 9, 2015
12:00 p.m. – 5:00 p.m. (ET)
Deloitte & Touche
New York, NY 10112
Note: Closed Meeting

 
 
SFIG & IMN's ABS VEGAS 2016 CONFERENCE

SUNDAY, February 28, 2016 – WEDNESDAY, March 2, 2016
The Aria Resort & Casino
Las Vegas, NV
Registration is 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.

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. For its first initiative, the committee commented on the Treasury Department's Request for Input on Online Marketplace Lending. The comments were submitted on September 30th and drafted by counsel at Chapman and Cutler LLP.

Members interested in participating should contact Amanda.Bateman@sfindustry.org.

SFIG’s Student Loan Committee recently responded to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans.

To join SFIG’s Student Loan Working Group and learn more, please contact Alyssa.Acevedo@sfindustry.org.

The RMBS 3.0 Task Force released its Second Edition RMBS 3.0 Green Paper in November of 2014. The task force’s most recent work product will be presented at the November 12th SFIG/IMN Private Label RMBS Symposium. 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; and (3) Role of Transaction Parties and Bondholder Communications. Presently, the task force is working on (1) developing a comprehensive compilation of representations and warranties for release in the fall of 2015 and (2) a grid summarizing roles of transaction parties. 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 submitted its comments on FHFA’s update to the single security initiative on October 7, 2015. The task force also recently received an update from the SFIG participants on the Industry Advisory Group for the Common Securitization Platform and Single-Security. 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 including the Johnson-Crapo bill and the PATH Act. Additionally, the task force will continue to engage the Federal Housing Finance Agency on its Single-Security proposal, guarantee fee pricing and Strategic Plan for 2015-2019.

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 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 Task Force.

The Risk Retention Industry Guide Working Group is 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 continues to hold discussions with a focus on SFIG’s partnership with the Chinese Securitization Forum, potential upcoming educational discussions and the sharing of recent market developments in China.

If you would like more information on SFIG’s work with respect to Chinese securitization, please contact 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
  • Provide input into IOSCO, BCBS and IAIS on the revitalization of securitization markets

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.

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 develop a comment letter when U.S. regulators release their proposed Net Stable Funding Ratio (“NSFR”).

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.

SFIG members who are interested in learning more about this initiative should email Amanda.Bateman@sfindustry.org.

The Money Market Fund Reform Working Group submitted a comment letter on October 13, 2014 regarding the Securities and Exchange Commission’s July 23, 2014 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 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.

To join the HQS Task Force, please contact Amanda.Bateman@sfindustry.org.

 
 
INDUSTRY NEWS HIGHLIGHTS
WATT SAYS GSEs MAY NEED TO DRAW ON TREASURY TO RESTORE CAPITAL

On Tuesday, November 3rd, Federal Housing Finance Agency Director Mel Watt said that Fannie Mae and Freddie Mac (“GSEs”) may require additional taxpayer assistance to restore their capital. The comments come after it was revealed that Freddie Mac’s Q3 losses amounted to $475 million, the first ever quarterly loss posted by a GSE during Watt’s tenure, according to an article in Inside Mortgage Finance.

Following the announcement of Freddie’s third quarter earnings, Watt stated:

Volatility in interest rates coupled with a capital buffer that will decline to zero in 2018 under the terms of the senior preferred stock purchase agreements with Treasury will likely make both Enterprises increasingly susceptible to the possibility of quarterly losses that could result in draws going forward.

Fannie Mae’s third quarter results are also expected to be reported this week.

 
 
MARKET CONCERNED ABOUT LIQUIDITY IMPACT AS BASEL INTENDS TO FINALIZE RULES BY END OF YEAR

Market participants are fearful that bond market liquidity may shrink if the proposed Basel Committee on Banking Supervision rule changes requiring banks to hold more capital are implemented, according to a recent Bloomberg article.

“The changes may require banks to set aside 60 percent more capital for U.S. Treasury holdings and 90 percent more for Japanese government bonds,” said Vanessa Le Lesle, head of regulatory affairs in the Asia-Pacific region for JPMorgan. “We are talking about quite liquid sovereign bonds that would be quite impacted, so even worse for emerging markets... All of that points to some reasons why banks would be less willing to provide liquidity.”

Stricter international bank capital regulations have already meant banks have less capacity to back their market-making business, where part of the role involves warehousing risk. The result is that prices can be more volatile for money managers and private investors, according to the article.

 
 
TREASURY ADVISOR HINTS AT NEW REGULATION OF SMALL BUSINESS LENDING

Antonio Weiss, Counselor to the Secretary of the U.S. Treasury, spoke on October 29th about the potential for more regulation of small business lending, as reported by Asset Securitization Report. His comments were made at IMN’s U.S. Marketplace Lending conference in New York, where SFIG was lead association supporter. Mr. Weiss discussed the main themes of responses to the Treasury Department’s Request for Input on Online Marketplace Lending, and stated with respect to small business lending that “many commenters highlighted the need to establish a level playing field,” between consumer and small business borrowers. He also referenced the self-regulatory efforts made by certain industry participants in the Small Business Borrowers Bill of Rights, stating that “policymakers will need to assess whether these efforts are successful in creating high standards across the industry.”

Mr. Weiss also called for a “balanced approach by the government” and said that “at Treasury, we will seek to foster, not impede, innovation that increases competition and broadens access to affordable credit for creditworthy borrowers and businesses.”

To read SFIG’s response on the Treasury Department's Request for Input on Online Marketplace Lending, please click here.

 
 
REMAINING AGENCIES FINALIZE SWAP MARGIN RULE

Last week, SFIG reported that the Federal Deposit Insurance Corporation approved a final rule to establish capital and margin requirements on non-cleared swaps for swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants, as required by the Dodd-Frank Act.

Following this, the remaining five federal agencies finalized the final swap margin rules on October 30th. These agencies include the Farm Credit Administration, the Federal Housing Finance Agency, the Federal Reserve, and the Office of the Comptroller of the Currency.

 
 
FHFA ANNUAL HOUSING REPORT RELEASED

On Friday, October 30th, the Federal Housing Finance Agency (“FHFA”) released its Annual Housing Report describing the 2014 housing activities of Fannie Mae and Freddie Mac (the “GSEs”). According to the report, the GSEs acquired $584.1 billion of loans on single-family owner-occupied housing and provided funding for 738,449 multifamily rental units in 2014. The report reviews preliminarily the GSEs’ performance under their 2014 statutory annual housing goals. While Fannie Mae met or exceeded all of its single-family housing goals, Freddie Mac failed to meet two: its Low Income Home Purchase Goal and its Very Low Income Home Purchase Goal. Both GSEs exceeded their Multifamily Housing Goals in 2014.

 
 
GINNIE TO SPEND FEWER RESOURCES ON ADDING NEW ISSUERS

Ginnie Mae says it will focus current resources less on bringing in new issuers and more on ensuring current issuers are fully participating in its program, according to an article in National Mortgage News. Ted Tozer, President of Ginnie Mae, said Monday at the Mortgage Bankers Association annual convention that Ginnie will focus on approved lenders that are not issuing mortgage-backed securities on a regular basis. “There are issuers who had previously created securities on a regular basis but right now are in 'runoff' mode and are driving up Ginnie’s costs,” Tozer said.

Edward Golding, Principal Deputy Assistant Secretary at the Department of Housing and Urban Development, addressed the issue of banks versus nonbanks in the context of the Federal Housing Administration’s mortgage insurance program. The article states that, “the rising participation of nonbanks is a concern for those who worry nonbanks hold less capital than banks.”

 
 
FITCH: U.S. CMBS LOAN DEFAULTS DECLINE SLIGHTY

According to a recent Fitch Ratings article, U.S. CMBS loan defaults have declined slightly to 13.2 percent as of third quarter 2015 due to lower new defaults and strong new issuance levels. This is down from 13.3 percent at the end of the second quarter of this year.

Office properties were the largest contributor to new third quarter defaults by loan balance, comprising 55.7 percent of total defaults. Retail properties were the second largest contributor at 31.8 percent of total defaults. According to the article, office and retail defaults were generally due to struggling occupancy levels and declining rents.

 
 
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

Mary Robinson Policy Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Amanda Bateman Policy Analyst

Daniel Tees Policy Analyst

Jennifer Serpas Office Manager

Allison Creswell Events Coordinator

Sarah Clarke Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

Structured Finance Industry Group
WebsiteEmail Us | Web Archive

linkedin
To unsubscribe from this email listing, please click here.

 


Informz
wagers
Terms and Conditions | Privacy Policy