October 7, 2015 Newsletter
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October 7, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


Today, October 7th, SFIG submitted comments to the Federal Housing Finance Agency (“FHFA”) in response to its Update on the Structure of the Single Security. The letter notes areas where SFIG is in agreement with FHFA on the development of a single security, including to-be-announced (“TBA”) market eligibility, inclusion of multiple-lender pools, disclosure requirements and key stakeholder involvement. However, SFIG remains concerned about the ultimate success of the single-security plan, due to the partial alignment of Fannie Mae and Freddie Mac’s policies and procedures, the selected implementation process and the necessity of an explicit Government guarantee.

SFIG’s comment letter, drafted by Chris DiAngelo at Katten, Muchin and Rosenman, was developed via its GSE Reform Task Force. To participate in the task force and learn more, please contact Amanda.Bateman@sfindustry.org.


SFIG is pleased to welcome Daniel Goodwin, our newest staff member. Dan joins SFIG as the Director of Mortgage Policy, bringing over 25 years of experience in securitization, principal finance, and M&A with exposure to a wide range of asset classes.

Most recently, he was Executive Vice President of Hilltop Holdings, a financial holding company based in Dallas, TX. Prior to that, Dan was a Managing Director at Bank of America Merrill Lynch, where held a variety of positions over the years, including: Head of Advisory Services, Head of Asset Securitization and Principal Investing – Originations, and Co-Head of Home Equity Banking providing advice and capital to commercial banks, money managers, specialty finance companies, and insurance companies. Before joining Bank of America predecessor NationsBank, in 1997, Dan held positions at Nomura Securities, Financial Security Assurance, and PaineWebber, all in mortgage related positions.

Dan holds a B.A. in Economics from Vassar College.

Dan can be contacted by email at Daniel.Goodwin@sfindustry.org or by phone at 202-524-6303.


Yesterday, October 6th, SFIG hosted its Marketplace Lending Symposium at the Washington DC offices of Chapman and Cutler LLP. Congressman David Schweikert of Arizona delivered the Keynote address, in which he lauded the industry for creating a new borrowing channel for consumers and small businesses to spur U.S. economic growth. Panelists discussed the various platform models and funding sources within marketplace lending, as well as the legal and regulatory landscape. Attendance reached capacity, including more than 75 industry participants and policymakers interested in this developing market.

SFIG's Marketplace Lending Committee submitted a response to the Treasury Department's Request for Input on Online Marketplace Lending on September 30th. The response was drafted by counsel at Chapman and Cutler LLP.

Members interested in joining the Committee should contact Amanda.Bateman@sfindustry.org.


Register now for SFIG’s Fall Symposium on Thursday, October 8th! The event will be hosted by PricewaterhouseCoopers at their New York City office.

High Quality Securitization: Sairah Burki, Senior Director of ABS Policy at SFIG, will discuss the HQS initiatives underway in Europe and at the Basel Committee on Banking Supervision and the International Organization of Securities Commissions. She will also provide an overview of discussions SFIG has had with U.S. regulators on HQS.

Marketplace Lending: Panel discussion moderated by Kristi Leo, Senior Advisor at SFIG.

Panelists include:

  • Adelina Grozdanova, VP, Head of Institutional Investors, Lending Club
  • Chuck Weilamann, Managing Director, DBRS
  • Joshua Rand, COO and Principal, Petra Partners
  • Karan Mehta, Head of Capital Markets, Marlette Funding
  • T.J. Gordon, Partner, Sidley Austin LLP

The full agenda can be found here.

THURSDAY, October 8, 2015
5:00 – 8:00 p.m. (ET)
300 Madison Avenue
New York, NY 10017

To register, please click here. Due to security concerns, walk-ins cannot be accommodated. Registration is open to SFIG members and non-member industry participants. This event is closed to the press. The symposium will be followed by a cocktail reception.


Register now for SFIG and IMN’s ABS Vegas 2016 Conference! The conference will be held at the Aria Resort & Casino in Las Vegas, NV on February 28 – March 2, 2016.

Keep an eye out in upcoming newsletters for speaker nominations. 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.

Sponsorship opportunities are available now! SFIG members receive special discounted rates for registration and sponsorship. Sponsorship of this event is not a guarantee of speaker placement. If you are interested in sponsoring, please contact Christopher Keeping at ckeeping@imn.org or 212-901-0533.

The ABS Vegas 2016 hotel room block will open within the next few weeks. Reservations in the discounted conference block are on a first-come-first-served basis, and are for registered attendees only. Booking instructions will be sent to registered individuals once the room block is open.

To register and view more information about the conference, please click here.

If you have any questions about the conference, please email events@sfindustry.org.


SFIG currently has a position open for:

  1. 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:

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
Associate Analyst 1   Moody’s Corporation 7-28-15
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 8, 2015
9:00 a.m. – 10:00 a.m. (ET)


FRIDAY, October 9, 2015
10:00 a.m. – 11:00 a.m. (ET)


FRIDAY, October 9, 2015
1:00 p.m. – 2:00 p.m. (ET)


TUESDAY, October 13, 2015
11:00 a.m. – 12:00 p.m. (ET)


WEDNESDAY, October 14, 2015
2:00 p.m. – 3:00 p.m. (ET)

  • 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)


THURSDAY, October 8, 2015
5:00 – 8:00 p.m. (ET)
PricewaterhouseCoopers LLP
300 Madison Avenue
New York, NY 10017

Please click here to register. The full agenda can be found here.

Please note, this event is closed to the press. Due to security concerns, walk-ins cannot be accommodated.


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

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


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

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.


Last Thursday, the Federal Housing Finance Agency (“FHFA”) released its fiscal year 2016 Annual Performance Plan. The Annual Performance Plan includes plans to issue a rule pertaining to the development of a secondary market for manufactured housing, continue work on an initiative to update the credit scoring model used by Fannie Mae and Freddie Mac, the government sponsored-enterprises (“GSEs”), and address GSE disputes with lenders. FHFA indicated that the final rule, expected within the next 12 months, would require the GSEs to expand services to rural areas and improve preservation of affordable housing. The performance plan presents these actions to better serve consumers and develop a secondary market for manufactured housing loans.

FHFA will “continue to assess the feasibility of leveraging alternative credit scores for underwriting, disclosure and pricing purposes, including operational and system implications,” as part of an initiative to update the GSEs' credit scoring models. In addition, FHFA will work on establishing a framework for addressing GSE disputes with lenders over selling and servicing defect remedies. The framework may include an alternative to loan repurchase.


According to an article in StreetInsider, the Trepp CMBS Delinquency Rate fell 17 basis points in September making it the best single-month improvement in the last 12 months. The delinquency rate for U.S. commercial real estate loans in CMBS is 5.28 percent, down 47 basis points year-to-date. “We still expect an uptick in delinquencies in the near future as the brunt of peak era maturities come due, but the Fed’s rate hike procrastination should push off an increase. If rates stay lower for longer, borrowers will refinance more easily with higher DSCRs all else equal,” said Joe McBridge, Research Associate at Trepp. A breakdown of U.S. CMBS delinquencies for September can be seen in Trepp, LLC’s September 2015 U.S. CMBS Delinquency Infographic.


According to a recent Bloomberg article, the European Union plan to revive capital markets by granting capital relief to simple, transparent and standardized (“STS”) securitizations is being met with skepticism by some market participants. Bloomberg states some analysts and lawyers have argued:

While banks will probably issue more asset-backed debt under the new rules, the promised reduction of capital charges may be insufficient and the category of simple products too narrow to spur a market revival… [a]nd since banks themselves will be buyers of many of top-rated portions of the transactions, the balance-sheet room may not be as ample as foreseen.

Last week, the European Commission published the details of its Capital Markets Union Action Plan, including the Securitization Regulation establishing criteria by which transactions qualify as STS, and an amendment to the Capital Requirements Regulation that grants capital relief to STS securitizations (see SFIG’s newsletter coverage on the announcement here). Bloomberg notes that the final language in the proposal deems originators as not compliant if their sole purpose is to securitize assets. As one industry lawyer tells Bloomberg, “They’ve adopted a ridiculously narrow view of what amounts to a ‘good’ securitization.”

As Europe searches for returns amid historically low interest rates, there has been a renewed interest in ABS from pension funds, according to a recent Financial Times article. This year, pension funds in Europe are gradually increasing their exposure to an ABS market still struggling to revive itself in the face of low issuance and stringent regulation.

European ABS yields have been low this year. As SFIG previously reported, the European Central Bank is buying ABS in Europe, but not in the U.K. This has created an opportunity for investors, according to Patrick Janssen, a portfolio manager at M&G Investments. The company has raised €1.5 billion ($1.68 billion) for ABS strategies, mainly from European pension funds.

“The type of clients we’re facing now are different — there are more pension funds,” said Mr. Janssen. “It’s become easier for managers to defend it [ABS] to their risk committees,” he added.

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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