September 29,  2016 Newsletter
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September 29, 2016
 
 
SFIG News

Industry Jobs

SFIG Calendar

Meetings

Events

Advocacy Outlook

Industry News Highlights

 
SFIG NEWS
200 WOMEN AND MEN ENJOYED WiS MIAMI RACE-OFF EVENT DURING ABS EAST

A large crowd enjoyed a fun afternoon at Eden Roc, playing lawn games and racing remote control cars on a track!

Winners of the elimination races and finals – pictured below – earned trophies as well as bragging rights, and can boast driving skills demonstrably superior to those of their structured finance colleagues.

We are proud to bring such fun-filled and educational events to the securitization community, where attendees enjoyed mingling with fellow industry professionals while competing in fun games, and also had the opportunity to learn about WiS’s new Career Mentor Program.

 
Photo by Jennifer Wolfe Photo by Andrew Milne Photography

Please stay tuned for more details on WiS’ next educational event:

WiS “Speed Securitization” Event

New York City
Thursday, October 27th
6:00 – 8:30pm
Location TBD

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ABS EAST 2016 A SUCCESS!

We are again proud to be the Lead Association Partner for last week's 22nd annual ABS East conference, hosted by IMN. The event welcomed over 3,300 industry participants to Miami Beach.

The first day included an “SFIG Advocacy Track”, which allowed SFIG staff and members to provide attendees with updates on important initiatives such as RMBS 3.0, Marketplace Lending, Investor Agenda, Investor Liquidity Review, and Regulation ABII/Disclosure.

Photo by Andrew Milne Photography

SFIG’s Women in Securitization initiative hosted a successful event at the Eden Roc Hotel on Sunday, as well as an informative panel on advocating for change on Tuesday. Thank you to all who attended and helped make the WiS event such a huge success!

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SFIG AUTO ISSUER COMMITTEE SUBMITS RESPONSE TO SEC FEEDBACK ON FORM ABS-EE TEST FILING; SFIG STAFF AND MEMBERS FOLLOW UP WITH A CALL WITH SEC

On Friday, September 16, 2016, SFIG’s Auto Issuer Committee submitted a letter to the U.S. Securities and Exchange Commission (SEC), responding to feedback regarding their Form ABS-EE test filings. This submission follows several other letters with the SEC regarding EDGAR ABS XML technical specifications, including an initial letter in September of 2015 and a follow-up letter in February of 2016. SFIG staff and members also had a call with SEC staff yesterday, September 28th, to discuss the letter in further details. 

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SFIG DISCUSSES CREDIT SCORING MODELS WITH FHFA

SFIG recently spoke with regulators at the Federal Housing Finance Agency (FHFA) to discuss the implementation of multiple credit scoring models.

Dan Goodwin, Director of Mortgage Policy, communicated SFIG’s advocacy of multiple models and the concerns of members about implementation, model calibration, and potential consumer confusion. Goodwin reported that the FHFA’s decision and implementation timelines are unclear at this time.

SFIG appreciates the FHFA’s willingness to discuss the matter, and hopes the industry will continue to be involved in the decision making process. For questions about the meeting, please contact Daniel.Goodwin@sfindustry.org. If you are a member of the residential mortgage community and wish to register for the GSE Reform Task Force, please contact Marshall.Bornemann@sfindustry.org.

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SFIG MEETS WITH CFPB REGULATORS TO DISCUSS TRID

SFIG staff and key members recently met with regulators at the Consumer Financial Protection Bureau (CFPB) about Know Before You Owe disclosure rules and reviewed the RMBS 3.0 TRID Compliance Review Scope document.

The CFPB sought general information about underwriting exception rates and secondary market acceptance of the Know Before You Owe rules. SFIG continues to communicate the concerns of members regarding market participants’ ability to cure disclosure form errors and the potential for assignee liability.

SFIG appreciates the CFPB’s willingness to discuss the matter, and hopes the industry will continue to receive additional clarity regarding compliance. For questions about the meeting, please contact Daniel.Goodwin@sfindustry.org. Members can log into the SFIG website to view SFIG’s RMBS 3.0 TRID Compliance Review Scope documentation. Non-members can purchase a copy here.

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SFIG ADVOCATES FOR CSP INITIATIVES BEFORE GAO

SFIG recently spoke with staff at the Government Accountability Office (GAO) about the Single Security (SS) and Common Securitization Platform (CSP) Initiatives.

Richard Johns, Executive Director, Tom McCrocklin, Director of Advocacy, and Dan Goodwin, Director of Mortgage Policy, updated GAO staffers on the input provided to the FHFA to-date and advocated for enhanced involvement in policy decisions regarding the direction and implementation of the SS and CSP Initiatives.

SFIG appreciates the GAO’s willingness to discuss the matter, and welcomes the opportunity to share members' thoughts and concerns regarding SS and CSP. For questions about the meeting, please contact Daniel.Goodwin@sfindustry.org or Thomas.McCrocklin@sfindustry.org. If you are a member of the mortgage community and wish to register for the GSE Reform Task Force, please contact Marshall.Bornemann@sfindustry.org.

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STILL TIME TO REGISTER: BLOCKCHAIN SYMPOSIA IN WASHINGTON, D.C. AND NEW YORK CITY

Everyone's heard of blockchain. But what does it mean for structured finance?

Join SFIG, in association with the Chamber of Digital Commerce, in its blockchain symposia series featuring speakers with extensive experience in and knowledge of securitization and blockchain technology. The series’ next installment will be in New York City on October 4th, covering the ways blockchain can impact structured finance and how to mobilize blockchain in order to connect tech to finance. On October 6ththe event in Washington, D.C. will continue the discussion on the interplay between blockchain and structured finance as well as potential policy and regulatory considerations.


The Washington, D.C. Symposium will be held on October 6th at Venable LLP at 575 7th Street NW, Washington DC, 20004 from 5pm-7pm, followed by cocktails. To register for this event, please click here.

This panel will be moderated by Val Srinivas, Research Leader, Banking & Capital Markets, Center for Financial Services, Deloitte. Val is an expert in financial information and technology industries. Panelists will include:

  • Kevin Batteh, Partner, Delta Strategy Group; General Counsel, Commodity Markets Council; Chief Policy Advisor, Chamber of Digital Commerce
  • Perianne Boring, President, Chamber of Digital Commerce 
  • Andrea Tinianow, Director of Corporate and International Development, State of Delaware
  • Carol Van Cleef, Partner, Manatt, Phelps & Phillips; Advisory Board, Chamber of Digital Commerce

The New York Symposium will be held on October 4th at the offices of Ernst & Young at 5 Times Square, New York, NY 10036 from 5pm-7pm, followed by a cocktail reception. To register for this event, please click here.

The panel will be moderated by Lewis Cohen, a Partner in the Capital Markets practice at Hogan Lovells. Lewis serves as co-chair of SFIG’s Blockchain Task Force, and has contributed to several publications relating to blockchain. Participants will include:

  • Emmanuel Aidoo, Director, Credit Suisse
  • Leo Efstathiou, Cofounder and CEO, Finsight
  • Scott Mehlman, Founding Partner, BCSI
  • Dan O’Prey, CMO, Digital Asset
  • Ron Quaranta, Chairman, Wall Street Blockchain Alliance; CEO, Digital Currency Labs
  • Eli Stern, Principal, Ernst & Young and recently
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REMINDER: SFIG COMMITTEE CO-CHAIRS NOMINATION NOW OPEN!

SFIG is now accepting nominations/re-nominations for its Committee Chairs for the 2017-2018 term.

The current SFIG Committee Chair terms will expire on December 31, 2016. Both new and existing chairs and co-chairs are eligible to be nominated.

Eligibility for a position on the committee leadership is limited to individuals employed by SFIG’s primary members. Members may nominate themselves or qualified industry participants.

Once the nomination window closes, SFIG’s Nominating Committee will review nomination submissions, consult with members and make recommendations to the SFIG Board of Directors. The Nominating Committee is dedicated to selecting a balance of co-chairs that is reflective of the membership and the industry at large, and is committed to working hard and advancing the principles of SFIG.

The Committee Chair terms are for two years. Nominations for the co-chairs will be accepted until Monday, October 31, 2016.

Please select one of the committees under “Committees Nomination Category” to nominate.

>> Nominate Here <<

**Please note that the nomination form is open to registered members only. Members that have not yet registered can do so here.**

If you have any questions or require any clarification around the nominating process, please email Committees@sfindustry.org.

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INDUSTRY JOBS

SFIG Positions

Are you or someone you know eager to join a supportive, hard-working and fun nonprofit team doing incredible work? Good news, SFIG has several openings! Please see the below job opportunities and help us spread the word by passing them along to anyone who might be a good fit:

  • Director of Education: will be responsible for the strategic development and execution of a comprehensive and robust in-person and online education and member development program.
  • RMBS/CMBS Policy Manager: will contribute to the design of, and help execute group-wide strategy efforts and initiatives in support of SFIG’s mortgage policy priorities.
  • Manager of Advocacy: will design and execute advocacy strategies, engage with Capitol Hill and federal regulatory agencies as well as support SFIG’s advocacy efforts through development and growth of its political action committee.
  • Policy Analyst: will support general policy initiatives and investor relations through direct member engagement, meeting facilitation, research and analysis.

You can also follow our Twitter @SFIndustryG at https://twitter.com/SFIndustryG to stay updated on all SFIG job opportunities.


Industry Positions

Some of the latest industry positions available include:

JOB TITLE COMPANY POSTING DATE
Director/Senior Director - Research and Criteria Leader Fitch Ratings 05-03-2016

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

Current members are encouraged to advertise open positions within their company on SFIG's website by filling out the form here.

For questions about positions at SFIG, please contact Jobs@sfindustry.org. For questions about the website jobs portal, please contact Website@sfindustry.org.

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SFIG CALENDAR
MEETINGS
SFIG BOARD OF DIRECTORS MEETING

THURSDAY, September 29, 2016
12:00 p.m. – 5:00 p.m. (ET)
Katten Muchin Rosen LLP
New York, NY
Note: Closed Meeting

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EQUIPMENT ISSUER COMMITTEE CALL

MONDAY, October 3, 2016
2:00 p.m. – 3:00 p.m. (ET)

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MARKETPLACE LENDING WEEKLY CALL

WEDNESDAY, October 5, 2016
4:00 p.m. – 5:00 p.m. (ET)

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EVENTS
NEW YORK CITY BLOCKCHAIN SYMPOSIUM

TUESDAY, October 4, 2016
5:00 p.m. – 7:00 p.m. (ET)
Ernst & Young LLP
New York, NY
Registration available here.

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WASHINGTON, D.C. BLOCKCHAIN SYMPOSIUM

THURSDAY, October 6, 2016
5:00 p.m. – 7:00 p.m. (ET)
Venable LLP
Washington, D.C.
Registration available here.

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SFIG VEGAS 2017 CONFERENCE

SUNDAY, February 26, 2017 - WEDNESDAY, March 1, 2017
Aria Resort & Casino
Las Vegas, NV
Registration available here.

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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.

The committee recently launched its “Best Practices” initiative to establish industry consensus and provide recommendations around one or multiple accepted approaches. The five established Best Practices work streams are 1) Data & Reporting 2) Representations & Warranties 3) Regulatory 4) Operational Considerations and 5) Enforcement.

The committee previously commented on the Treasury Department's Request for Input on Online Marketplace Lending on September 30, 2015.

SFIG’s Student Loan Committee responded to Fitch’s proposed amendments to FFELP student loan ABS rating methodology earlier this year. The committee also submitted a response to the Proposed Changes to Moody’s Approach to Rating Securities Backed by FFELP Student Loans in October 2015.

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

The RMBS 3.0 Task Force released its Third Edition RMBS 3.0 Green Papers in November 2015. 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; 3) Role of Transaction Parties; and 4) 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 its 2016 agenda, the task force will address topics including the inclusion of an independent Deal Agent in transactions, Bondholder Communications, Data and Loan-Level Disclosure, Repurchase Enforcement, and Settlements, as well as undertake a review of the previously published Green Papers.

For additional information on RMBS 3.0, please contact Marshall.Bornemann@sfindustry.org.

In response to a request for public comment issued by FHFA on the GSEs’ credit risk transfer processes, SFIG, through its GSE Reform Task Force, convened a call on July 7th to gauge membership’s interest. The task force is currently working on a response to be submitted no later than October 13, 2016.

To join SFIG’s GSE Reform Task Force and learn more, please contact Marshall.Bornemann@sfindustry.org.

The Mortgage Loan Level Disclosure Task Force will soon begin its review of the Mortgage Industry Standards Maintenance Organization’s (MISMO) work to map the data elements that lenders should deliver in securitizations per the recent Regulation AB II release of Schedule AL. The requirements will come into effect in November 2016, and SFIG has participated in weekly conference calls with MISMO for the last 18 months in an effort to standardize disclosure by that time. SFIG encourages subject-matter experts from member organizations to participate in its review—which will be conducted jointly by this task force and the RMBS 3.0 Due Diligence, Data and Disclosure Working Group—so the work can be adopted as an industry-wide standard.

Members interested in participating should contact Marshall.Bornemann@sfindustry.org.

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 Alyssa.Acevedo@sfindustry.org to participate on the Task Force.

The Risk Retention Industry Guide Working Group launched its interim Industry Guide, ahead of the RMBS compliance date, focused on issues either relevant to all asset classes or specific to RMBS. The Working Group continues to work on a final guide focused on 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 completed their White Paper, A Comprehensive Guide to U.S. Securitization, in April for Chinese regulators and the Chinese Securitization Forum to educate them on the U.S. securitization landscape. The committee also continues to hold discussions with a focus on SFIG’s partnership with the CSF, 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.

The Regulation AB II Task Force has been focused on the disclosure and offering process requirements within the final rule. Asset specific work streams have been formed to develop comment letters on the outstanding proposals within the final rule and the Task Force submitted the first part of its comment letter in June of 2015. SFIG submitted a supplemental comment letter covering credit card and equipment floorplan asset classes on January 12, 2016 and another supplemental comment letter regarding asset-level information for student loans on June 15, 2016.  Future discussions across asset class committees and the Regulation AB II Task Force will focus on the remaining outstanding proposed rules, including potentially requiring issuers to provide the same disclosure for Rule 144A offerings as required for registered offerings.

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 recently submitted a response to the U.S. proposed net stable funding ratio (NSFR) requirements. The committee also recently submitted comments to the Federal Reserve Board’s (FRB) proposal regarding Single-Counterparty Credit Limits, and before that, submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations. The committee will be addressing industry concerns related to the FRB’s Final Rule on the Liquidity Coverage Ratio (LCR). SFIG testified before Congress in February 2016, focusing on global regulatory issues, including LCR, that affect lending across all asset classes.

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. In October 2015, the prudential regulators approved a Joint Final Rule on Swap Margin Requirements. In November 2015, the CFTC issued their final rule regarding margin requirements for uncleared swaps for swap dealers and major swap participants.

The High Quality Securitization (HQS) Task Force submitted a response to Basel’s Consultative Document regarding Capital Treatment for STC Securitisations in February 2016. The task force previously 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. SFIG testified before Congress in February 2016, focusing on global regulatory issues, including HQS, which affect lending across all asset classes.

To join the HQS Task Force, please contact Alyssa.Acevedo@sfindustry.org.

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INDUSTRY NEWS HIGHLIGHTS
SURGE IN ABS ISSUANCE AS U.S. ELECTION AND FRB MEETING APPROACH

Banks are ramping up ABS issuance with the approach of a Federal Reserve (FRB) meeting and the U.S. presidential election, two events that may unsettle markets, according to a recent Financial Times article.

Immediately prior to the ABS East conference, new supply hit its highest weekly level since September 2014, according to data from S&P Global Ratings. As the Financial Times reports, approximately $19 billion of U.S. ABS were sold in the week of September 16th, including $13 billion of securities backed by auto, credit card and other consumer product loans.

The FRB left interest rates unchanged after meeting last week, and traders and investors now bet the U.S. central bank will lift rates at its final meeting of 2016, according to the article.

“The ABS market is on fire,” said James Shepard, co-head of investment grade debt capital markets at Mizuho. “Whatever upsets this market is unknowable. We point to the presidential election, but that is probably a bump in the road. Something that completely reverses things has yet to be determined.”

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CFPB TO LENDERS: COMPLIANCE STRUCTURES FINALLY ADJUST TO RULES

According to a recent National Mortgage News article, the Consumer Financial Protection Bureau (CFPB) is satisfied with banks’ compliance structures. The CFPB officials acknowledge that banks’ internal compliance structures have “adjusted” to mortgage origination rules created under Dodd-Frank.

In the article, Peggy Twohig, the CFPB’s assistant director of supervision policy, says that “both banks and non-banks have generally adjusted their business models and practices to comply with the new mortgage origination rules.”

The article also quotes Mortgage Bankers Association President and Chief Executive David Stevens, who agrees with Twohig’s observation regarding lenders’ compliance systems. “They are working well,” said Stevens, but stressed the need for greater clarity by the Department of Housing and Urban Development (HUD) regarding underwriting standards.

“I think HUD has gone part way to give us some clarity,” according to Stevens. Lenders have been fined significantly for violating underwriting standards under the False Claims Act.

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GERMANY CHALLENGES ECB’S BOND-BUYING PROGRAM

On Wednesday, September 28th, several members of the German parliament told European Central Bank (ECB) President Mario Draghi that the bank's bond-buying program has gone too far, according to a recent Reuters article.

Michael Stuebgen, a conservative member of the German parliament, and his colleagues asked Draghi during his appearance in the Bundestag to explain his policies and answer questions from lawmakers. "It is time for the ECB to change course," Stuebgen said.

Draghi rejected German criticism that sub-zero interest rates were impoverishing savers and straining top lenders, saying its monetary policy was a necessity to get the euro zone back on the path to growth and revive inflation, according to another Reuters article.

The ECB is widely expected to announce an extension of its bond-buying program by the end of the year. The program is due to expire in March. According to Reuters, the ECB could also announce steps to broaden the scope of what it can buy in response to a dwindling pool of available assets as early as next month.

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FIRST NPL SECURITIZATION TO TAKE PLACE UNDER ITALIAN GOVERNMENT GUARANTEE PROGRAM

On Thursday, September 22nd, it was reported that Banca Popolare di Bari SCpA will be the first Italian bank to securitize a portfolio of non-performing loans (NPLs) under a new government guarantee program. Under this program, the small cooperative bank will buy state guarantees on the least-risky portions of the security, assuming those notes have an investment grade credit rating.

A recent article in Bloomberg highlights that this deal, being the first of its kind, will set the standard for how the Italian government uses this program moving forward. The securitization, made up of 480 million euros ($539 million) of NPLs, will completely remove the bad debt from the bank’s balance sheet.

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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

Dan Goodwin Director, Mortgage Policy

Tom McCrocklin Director, Advocacy

Jennifer Wolfe Manager, ABS Policy

Hua Liu Communications & Social Media Manager

Alyssa Acevedo Senior Analyst, ABS Policy

Marshall Bornemann, Policy Analyst

Robert Robilliard, Data and Policy Analyst

Jennifer Serpas Office Manager

Sarah Clarke Events Coordinator

Dani Hernandez Executive Administration

1775 Pennsylvania Ave. NW
Suite 625
Washington, DC 20006

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