September 23, 2015 Newsletter
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September 23, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


SFIG is pleased to welcome Dan Goodwin, our new Director of Mortgage Policy. Mr. Goodwin will focus on MBS policy issues and will report directly to SFIG's Executive Director, Richard Johns.

"We are thrilled to have such a talented senior executive on board at SFIG, especially one who brings a highly regarded status in the industry and impressive depth of subject matter knowledge to our organization," said Mr. Johns. "I believe SFIG's members will be well-served by Dan's expertise in housing finance as well as broader capital markets. His leadership roles across Bank of America Merrill Lynch not only provided Dan with deep subject matter expertise, but also strong relationships across all players in the sector."

Mr. Goodwin stated, "I am honored to join the SFIG team and look forward to working with SFIG's members and the executive team to continue to build upon the incredible momentum they have generated, particularly in invigorating the MBS market.” Mr. Goodwin also said, "SFIG has shown clear and powerful leadership in our industry through its collaborative, industry-wide RMBS 3.0 initiative and I am excited to be a part of the team that continues to bring together all the voices of this sector to deliver reform that will provide meaningful value to the real economy."

SFIG has worked with its full membership to revitalize the MBS market by identifying and addressing issues, and finding consensus solutions that do not require a regulatory mandate. The organization has made significant headway through the RMBS 3.0 initiative – a broadly supported endeavor designed to develop industry best practices and reduce substantive differences existing in the current RMBS market.


SFIG was proud to be the Lead Association Partner for last week's 21st annual ABS East conference, hosted by IMN. The event welcomed over 4,000 industry participants, a new record for the ABS East franchise.

The first day’s keynote address, moderated by SFIG’s Executive Director Richard Johns, focused on “Single Security & the Common Securitization Platform” and featured David Applegate, CEO at Common Securitization Solutions, LLC, and Robert Fisherman, Senior Associate Director at the Federal Housing Finance Agency, Renee Schultz, Senior Vice President at Fannie Mae and Mark Hanson, Senior Vice President at Freddie Mac. The second day’s keynote address focused on the future of residential mortgage finance and featured Edward DeMarco, former Director at the Federal Housing Finance Agency, as well as James Lockhart III and Armando Falcon Jr., both former Directors at FHFA’s predecessor agency, the Office of Federal Housing Enterprise Oversight.

The ABS East program included comprehensive coverage on the revival and strengthening of the U.S. securitization market.

The full collection of presentations from Miami can be accessed by clicking this link.


SFIG and IMN are excited to announce the agenda for the 2nd Annual Private Label RMBS Reform Symposium, taking place Thursday, November 12th in New York City. The event will build on last year's successful inaugural meeting, which featured more than 300 of the private label mortgage market’s most active investors, issuers, key regulators and service providers.

2015 Sessions Include:

  • State of the Non-Agency Market
  • What’s New in PLS RMBS Reform?
  • Proposed Deal Manager/Agent Frameworks
  • Overview of the New Comprehensive Reps & Warranties Provisions
  • Servicer Oversight & Enforcement
  • Impact of Regulations on the RMBS Market
  • The Credit Risk Transfer Program: Impact on PLS RMBS
  • Paving the Way for Expanded Credit/Non-QM Products
  • The RMBS Investor Perspective: How Can Investors Proactively Help Widespread Uptake of 3.0's Standards?
  • Strategies for Encouraging Issuer Adoption

To view the full agenda, please click here.

The 2015 program will provide key updates on progress made in SFIG’s RMBS 3.0 initiative, with a particular emphasis on reps and warranties standards and the deal manager framework. Other market restoring initiatives will be featured, as will a detailed look into the impact of new standards in emerging areas of the mortgage market such as non-QM.

Sponsorship opportunities are now available. For more information, please contact Christopher Keeping at IMN by email,, or by phone at 212-901-0533.

To register for the Symposium, please click here


SFIG is pleased to announce Congressman David Schweikert (R-AZ) as Keynote Speaker for the Marketplace Lending Panel Discussion on Tuesday, October 6th hosted by Chapman and Cutler LLP. Register for this Symposium in order to learn more about marketplace lending, and interact with attendees from five Federal regulators and the Department of Treasury, as well as staff representing key members of both the House Financial Services and Senate Banking Committees. 

The panel discussion will include:

  • Differing Marketplace Lending Business Models
  • The Nexus with Securitization
  • The Effect on Consumer Lending

Full agenda will be forthcoming.

TUESDAY, October 6, 2015
5:30 – 8:00 p.m. (ET)
Chapman and Cutler LLP
1717 Rhode Island Ave. NW
Washington, DC 20036

To register, please click here. This educational event is complimentary for all attendees. Registration will begin at 5:30 p.m. A networking cocktail reception will follow. This event is closed to the press. Due to security concerns, walk-ins cannot be accommodated.


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:

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
Mid-level Asset Securitization Associate Attorney   Chapman and Cutler LLP 7-01-15

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

For questions about positions at SFIG, please contact For questions about the website jobs portal, please contact

  • THURSDAY, September 24, 2015
    10:00 a.m. – 11:00 a.m. (ET)
  • THURSDAY, October 1, 2015
    10:00 a.m. - 11:00 a.m. (ET)
THURSDAY, September 24, 2015
11:00 a.m. - 12:00 p.m. (ET)
MONDAY, September 28, 2015
2:00 p.m. - 3:00 p.m. (ET)
THURSDAY, September 29, 2015
11:00 a.m. – 12:00 P.m. (ET)
WEDNESDAY, September 30, 2015
2:00 p.m. – 3:00 p.m. (ET)

TUESDAY, October 6, 2015
5:30 – 8:00 p.m. (ET)
Chapman and Cutler LLP
1717 Rhode Island Avenue NW
Washington, DC 20036
Please click here to register. Full agenda will be forthcoming.

Please note, this event is closed to the press


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. Full agenda will be forthcoming.

Please note, this event is closed to the press and seating priority will be given to SFIG members.


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 available here


THURSDAY, November 12, 2015
Marriott New York Downtown
New York, NY
Registration available here


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


If you would like to participate in the work SFIG is undertaking through our committees as highlighted below, please e-mail For specific inquiries on any of SFIG’s advocacy efforts, please contact the staff member listed for the related project.

SFIG’s Marketplace Lending Committee was established in August 2015, as an SFIG participant committee and is open to all SFIG members who have a legitimate interest in marketplace lending. The committee was formed with two primary intentions: 1) to work with members involved in marketplace lending to educate the industry as a whole, with a particular focus on the securitization of assets generated through that lending channel; and 2) to determine appropriate securitization-specific policy and engage in related advocacy, leveraging SFIG’s prominence and experience across all asset classes to support the continued responsible growth of securitization in marketplace lending. The committee's first initiative will be to respond to the Treasury Department's Request for Input on Online Marketplace Lending, due September 30th. Peter Manbeck and Marc Franson of Chapman and Cutler LLP are serving as drafting counsel.

Members interested in participating should contact

SFIG’s Student Loan Working Group 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

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

The GSE Reform Task Force reviewed a draft response to the FHFA’s update to the single security initiative earlier this month. 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

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 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 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 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

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

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

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

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

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

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


Last Wednesday, September 16th, the U.S. Securities and Exchange Commission (“SEC”) released updated compliance and disclosure interpretations for legacy deals (offerings made before the November 23, 2016 compliance date for Regulation AB II). The SEC clarified that “asset-level data requirements are applicable only to securitizations in which the initial bona fide offer occurs on or after November 23, 2016.” Offerings on or after this date must provide asset-level disclosure in accordance with the requirements of Regulation AB II in the prospectus at the time of the offering and then on an ongoing basis with each Form 10-D filing.

The SEC also stated that “[s]ecuritizations for which offers are made prior to November 23, 2016 are not required to provide asset-level disclosures in the prospectus or on an ongoing basis with each Form 10-D.”

This clarification confirms the preliminary feedback SFIG had received from SEC staff on September 2nd regarding asset-level disclosure for legacy deals.


The Board of the International Organization of Securities Commissions (“IOSCO”) has published its final report on the Peer Review of Implementation of Incentive Alignment Recommendations for Securitisation, which evaluates progress made by several jurisdictions in adopting legislation, regulation and other policies in relation to incentive alignments in securitization.

The Incentive Alignment Recommendations call for national authorities to:

  1. Evaluate incentives across the securitization value chain, and formulate and implement approaches to incentive alignment
  2. Set out the elements of the incentive alignment approach, including risk retention
  3. Seek to minimize the potentially adverse effects to cross-border securitization transactions resulting from differences in approaches to incentive alignment and risk retention

The review found that participating jurisdictions have made significant but mixed progress in implementing the Incentive Alignment Recommendations. The review also reported progress only on implementation of Recommendations 1 and 2 as a review of implementation of Recommendation 3 was seen to be premature at this stage. European Union jurisdictions and the United States are viewed as having progressed further in their implementation than many jurisdictions with smaller securitization markets.


According to a recent Moody’s Investors Service announcement, the securitization of non-bank loans is contributing towards European policymakers’ initiatives to fund small businesses and expand the non-bank lending market.

"Securitization enables investors, such as insurers and pension funds, to transform their investments into more liquid instruments and to align their risk appetite, owing to the tranching of issued notes," stated Monica Curti, Vice President & Senior Credit Officer at Moody's.

According to its report, “Securitisation Will Enhance Policy Makers' Initiatives to Develop Non-Bank SME Lending,” Moody’s expects securitization to emerge as a new funding source for small and medium-sized enterprise (“SMEs”) and mid-caps in Europe. Policymakers are supporting non-banks’ SME lending activities while encouraging investors to support growth in the real economy. Curti stated:

Data on SME and mid-cap debt originated by non-banks is fragmented at best. This exposes the deal to risks, such as an adverse pool cut, or a potential misalignment of interest between investors and portfolio managers. With traditional bank lending to SMEs in the euro area well below pre-crisis levels, alternative investors can undertake lending directly in the case of private placements, through a fund or a special-purpose vehicle.


According to former Director of the Federal Housing Finance Agency (“FHFA”) Ed DeMarco, while the 30-year fixed rate mortgage may be considered sacrosanct in the U.S., borrowers should be encouraged to pay down mortgage loans faster. Speaking during the Keynote address at IMN’s ABS East Conference, for which SFIG acted as lead association sponsor, Demarco told audiences that taking out a 30-year fixed rate mortgage is “just bad financial advice for many Americans” and can mean that as a borrower “you are paying a tremendous amount for the option to refinance that mortgage.”

Not all industry experts share DeMarco’s view that the 30-year fixed rate product spurs excessive mortgage debt. As highlighted in a recent Bloomberg article, Pershing Square Capital Management founder Bill Ackman argued that taking that product away would lead homeownership rates to drop, with the result that properties “are going to materially decrease in value.” SFIG has taken a similar position in its GSE Reform Briefing Book and Congressional testimony, noting that “oth [the TBA market and a fixed rate mortgage] have provided valuable benefits to borrowers, including the ability to most efficiently lock-in an interest rate early in the mortgage process.”


Last Wednesday, a bipartisan Senate group reintroduced the “Jumpstart GSE Reform Act”, originally introduced in 2012. The bill would block Congress from using revenues collected by Fannie Mae and Freddie Mac (collectively, “the GSEs”) as guarantee fees (“g-fees”) to cover unrelated spending. The bill, sponsored by Sens. Elizabeth Warren (D-MA), Bob Corker (R-TN), Mark Warner (D-VA), and David Vitter (R-LA), comes after lawmakers attempted to direct g-fees to fund a still-pending transportation bill over the summer. Introduction of the language is designed to remove outstanding hurdles to GSE reform, though critics of the proposal are concerned it may make unwinding the GSEs more difficult.


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 of Advocacy

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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