October 14, 2015 Newsletter
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October 14, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


SFIG is proud to be the lead association supporter at IMN’s Investors’ Conference on Marketplace Lending on October 29th at the Marriott Downtown in New York City. Over 300 asset managers, private equity/venture capital and traditional institutional investors are registered to attend. They will be joined by many of the leading platforms and service providers to this growing industry to learn about:

  • The outlook and potential impact of new regulations on the sector
  • The importance of securitization as a funding tool
  • Risk management/investor reporting developments
  • Investment strategies for debt and equity buyers
  • The European market, and cross border opportunities for U.S. platforms and investors

The following SFIG staff will be participating in the event: Jennifer Wolfe, ABS Policy Manager, will be speaking on the “Thought Leadership & the Future of Regulation in US Marketplace Lending” panel; Richard Johns, Executive Director, will be speaking on the “Development of Securitization in Marketplace Lending” panel; and Kristi Leo, Senior Advisor, will moderate the “Marketplace Lending & the Lenders' Perspective” panel.

Keynote speakers will include: Ron Suber, President at Prosper Marketplace, Inc.; Antonio Weiss, Counselor to the Secretary at U.S. Department of Treasury; and Raj Date, Managing Partner at Fenway Summer LLC.

To register, please click here. For more information on sponsorship, please contact Christopher Keeping at ckeeping@imn.org or at 212-901-0533.


Last Thursday, October 8th, SFIG held its 2015 Fall Symposium at the New York City offices of PricewaterhouseCoopers. SFIG Senior Director of ABS Policy Sairah Burki opened the symposium with a discussion of recent developments related to high quality securitizations (“HQS”), including the final Basel Committee on Banking Supervision and International Organization of Securities Commissions framework and the adoption of related legislation by the European Commission as part of its Capital Markets Union Action Plan.

Following the overview of HQS, SFIG Senior Advisor Kristi Leo moderated a panel that included representatives from two marketplace lending platforms, an investor, lawyer and rating agency expert. The panel provided an overview of the marketplace lending industry, including differences in business models, ratings implications and servicing standards.

SFIG is actively engaged in advocacy on both HQS and marketplace lending. To join either committee and learn more, please contact Amanda.Bateman@sfindustry.org.


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:

Finance Associate   Hogan Lovells US LLP 10-09-15
Attorney - Securitization   Ford Motor Credit Company 9-29-15
Consumer ABS Analysts   Kroll Bond Rating Agency, Inc. 8-19-15
Senior Vice President, RMBS Monitoring   Moody’s Corporation 8-18-15
Associate Analyst 1   Moody’s Corporation 7-29-15
Vice President, Senior Credit Officer (ABS Surveillance)   Moody’s Corporation 7-31-15
Associate Analyst 3   Moody’s Corporation 7-29-15
Capital Markets Associate   Cadwalader, Wickersham & Taft LLP 7-21-15
Director - Credit Process Management   Fitch Ratings 7-09-15
Associate Director / Director, Asset Backed Securities   Fitch Ratings 7-08-15

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.

  • THURSDAY, October 15, 2015
    10:00 a.m. – 11:00 a.m. (ET)
  • THURSDAY, October 22, 2015
    10:00 a.m. – 11:00 a.m. (ET)

FRIDAY, October 16, 2015
2:00 p.m. – 3:00 p.m. (ET)


MONDAY, October 19, 2015
2:00 p.m. – 3:00 p.m. (ET)


THURSDAY, October 22, 2015
1:00 p.m. – 2:00 p.m. (ET)


WEDNESDAY, October 14, 2015 – THURSDAY, October 15, 2015

Workshop: Clifford Chance's Office, Hong Kong
Main Conference: Conrad Hong Kong, Grand Ballroom, Lower Lobby, Hong Kong

  • Sairah Burki will speak at the "Developments in the US/EU Securitization and Covered Bonds Markets” workshop
  • Richard Johns will be a discussion leader on the "Impact of European Regulation (AIFMD, CRD II/IV, CRA3) and US Regulation (Volker, Dodd-Frank and Commodity Pool Operator)" roundtable

More information on the conference can be found here.


THURSDAY, October 29, 2015
Marriott New York Downtown
New York, NY

  • Jennifer Wolfe will be speaking on the “Thought Leadership & the Future of Regulation in US Marketplace Lending” panel
  • Richard Johns will be speaking on the “Development of Securitization in Marketplace Lending” panel
  • Kristi Leo will be moderating the “Marketplace Lending & the Lenders’ Perspective” panel

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


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

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

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


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


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 is focusing on and responding to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans. SFIG submitted an extension request on August 14th and Moody’s announced the deadline for comments has been extended to October 30th.  

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.


On October 7th, the Treasury Department’s Office of Financial Research (“OFR”) published a working paper on the Liquidity Coverage Ratio (“LCR”) under both Basel and the final U.S. rule. The paper demonstrates how the LCR would be calculated under both regimes, and identifies difficulties in interpreting LCR calculations and making comparisons across institutions. Most notably, the paper notes that due to “potential negative signaling effects, banks are likely to feel pressure to maintain LCRs above 100 percent even during times of stress.” This is an unintended consequence of the rules, which were intended to strengthen the banking system in the wake of the crisis by reducing systemic risk and increasing bank liquidity. The paper also cites other research finding that the “LCR could have unintended negative effects on interbank funding and interest rates through interactions with monetary policy.”

In the U.S., the LCR rule will be fully phased in by January 2017.


Sales of U.K. nonconforming mortgage-backed securities have reached their highest level since the financial crisis according to an article in Financial Times. Total issuance has reached €3.4 billion ($3.9 billion) so far this year, compared to €1.8 billion ($2 billion) in 2014. According to the article, “[t]hese type of home loans, which do not meet strict high street lending criteria, are now a major driver of the UK’s overall securitization market, representing around a quarter of total issuance of U.K. residential MBS so far this year.” The growth of nonconforming MBS is a result of lending from U.K. challenger banks (banks that contest the big, established lenders in the UK banking market) and non-traditional institutions who have filled a void vacated by high street institutions (large retail banks which have many branch locations). “It’s almost a reflection of the health of the housing and labour markets that this type of lending has emerged,” said Gareth Davies, head of asset backed security strategy at JPMorgan.


A National Resources Defense Council (“NRDC”) article has drawn attention to benefits of MBS backed by high-efficiency homes. According to the article, investors may prefer MBS backed by these homes and some pension funds may seek to support their state’s policy goals by improving efficiency of the building stock. The piece goes on to suggest that others may argue that loans for high-efficiency houses could out-perform loans for regular homes. Houses built to higher energy standards usually maintain higher property values relative to the market and offer lower utility expenses for residents, according to the NRDC. Ultimately, the article calls for transparency among MBS issuers so that investors have the information needed to direct their funds to support high-efficiency housing.


According to a recent article in MarketWatch, U.S. CMBS delinquencies fell six basis points in September to 4.46 percent, down from 4.52 percent the previous month. The data comes from the latest index results from Fitch Ratings, which also shows retail late-pays trending slightly higher. As stated in the article, “[r]esolutions of $688 million in September edged out new delinquencies of $624 million. Meanwhile, Fitch-rated new issuance of $8.7 billion in August (10 transactions) exceeded $5.3 billion in portfolio runoff, causing an increase in the index denominator.” During the past 12 months, the overall delinquency rate has fallen over 31 basis points due in part to improvements in hotel and multifamily. Retail, however, continues to lag, despite healthy new issuance.


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

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