September 8,  2016 Newsletter
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September 8, 2016

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


SFIG is pleased to announce the continuation of its blockchain symposia series this fall. The series will continue 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 6th, the event in Washington, D.C. will cover policy and regulatory obstacles that may arise in the application of blockchain to the structured finance industry.

To register for the event in New York City (October 4th) please click here.

To register for the event in Washington, D.C. (October 6th) please click here.

If you would like to join SFIG’s Blockchain Task Force, please contact

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With almost 4,000 people already registered for IMN’s ABS East conference next week, the conference is on track to be the most well-attended ABS East conference to date!

Don’t miss SFIG staff and members participating across multiple panels and events covering market and policy issues.

We will also be hosting our Women in Securitization event on Sunday afternoon, where we will Bring the Outdoors Inside with an indoor Garden Party/Regatta themed event at the Eden Roc. This event will include the launch of our Executive Career Sponsorship program - so whether you are male or female, if you are in a position to enable female career development, then this is an event you won’t want to miss. To register for this event, please click here.  

We look forward to seeing you all there, and don’t forget to stop by the SFIG booth to pick up your supply of free CDC-recommended bug repellent, if you are looking to venture outdoors and away from the conference area.

Of note, we would highlight the following agenda items (please be aware these sessions require advanced registration which may be confirmed with Melissa Igbineweka at

SUNDAY, September 18, 2016
Track C

12:30pm – 1:15pm:
RMBS 3.0 – Returning Private Capital to the Mortgage Market
          Daniel Goodwin (SFIG) & Eric Kaplan

1:15pm – 2:00pm: Marketplace Lending
          Jennifer Wolfe (SFIG) & William Black

2:15pm – 3:00pm:
Q4 2016 SFIG Investor Agenda and 2017 agenda
          Kristi Leo (SFIG) & SFIG Investor Cabinet

3:00pm – 3:45pm:
Investor Liquidity Review – The Path Forward
          Kristi Leo (SFIG) & SFIG Investor Cabinet

3:45pm – 4:30pm: Reg AB/Disclosure
          Alyssa Acevedo (SFIG) & Charles Sweet

Don’t miss SFIG staff speaking at the panels below!

MONDAY, September 19, 2016

11:15am: Track D
Risk Retention Compliance
Sairah Burki

2:00pm: Track D
Update on STS and Other Global Market Standards Initiatives
Richard Johns

TUESDAY, September 20, 2016

11:50am: Track D
Securitization Markets in China
Richard Johns

10:00am: Plenary Session
Women in Securitization – An SFIG Initiative
Moderated by Wendy Cohn, Managing Director, Fitch Ratings
Patricia Evans, Vice President, Wilmington Trust
Tricia Hazelwood, Managing Director, Head of Structured Products, MUFG
Carol Hitselberger, Partner, Mayer Brown LLP
Howard Kaplan, Partner, Deloitte & Touche LLP
Doug Murray, Managing Director, Fitch Ratings
Gregg Silver, President & CFO, 1st Financial Bank USA

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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 to stay updated on all SFIG job opportunities.

Industry Positions

Some of the latest industry positions available include:

Analyst/Associate Director - Asset Backed Securities Fitch Ratings 07-15-2016
Director/Senior Director - Asset Manager Leader Fitch Ratings 05-03-2016
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 For questions about the website jobs portal, please contact

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MONDAY, September 12, 2016
2:00 p.m. – 3:00 p.m. (ET)

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MONDAY, September 12, 2016
2:00 p.m. – 3:00 p.m. (ET)

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WEDNESDAY, September 14, 2016
4:00 p.m. – 5:00 p.m. (ET)

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THURSDAY, September 15, 2016
10:00 a.m. – 11:00 a.m. (ET)

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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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SUNDAY, September 18, 2016
3:00 p.m. – 5:00 p.m. (ET)
Eden Roc Hotel, Ocean Tower Ballroom II
Miami Beach, FL
Registration available here.

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SUNDAY, September 18, 2016
12:30 p.m. – 4:30 p.m. (ET)
Please note special sessions require advanced attendance which may be confirmed with Melissa Igbineweka at

These sessions are closed to the press.

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SUNDAY, September 18, 2016 – TUESDAY, September 20, 2016
The Fontainebleau
Miami Beach, FL
Registration available here.

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

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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 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

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

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

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

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 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 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

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

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

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

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On Friday, September 2nd, the Bureau of Labor Statistics released its monthly jobs report for August, calculating that the U.S. economy had added 151,000 non-farm payrolls and maintained a 4.9 percent unemployment rate. The number fell below many economists’ expectation of 180,000 new jobs for the month of August. It also represented a significant drop in new jobs added relative to an average of 263,000 for the months of July and August.

Taken together these factors have dampened the market’s expectations of a federal funds rate increase by the Federal Open Market Committee (FOMC) at the group’s September 21st meeting. A recent article by CNBC notes that, following a review of several “top banks’” predictions for the timing of the FOMC’s next rate hike, a majority find December a more likely month than September for the Committee to take action.

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Last week, on August 31st, the U.S. Securities and Exchange Commission (SEC) proposed rule and form amendments that would require registrants to include a hyperlink to exhibits in their filings.

According to a press release from the SEC, the proposed amendments would require registrants that file registration statements and periodic and current reports that are subject to the exhibit requirements under Item 601 of Regulation S-K, or that file on Forms F-10 or 20-F, to include a hyperlink to each exhibit listed in the exhibit index of the filings. The amendments would also require that registrants submit all of these filings in HTML format. 

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The European Central Bank’s (ECB) quantitative easing (QE) program topped 1 trillion euros ($1.124 trillion) this week after 18 months of aggressive bond buying, according to a MarketWatch article.

Late last year, SFIG reported that the ECB extended its QE program by six months, hoping to “add €680 billion – some 6.5 percent of the euro area GDP – in liquidity to the system by 2019…”

As MarketWatch explains, the ECB is using a so-called "capital key" to determine how many bonds from each country it should buy, with the amount proportional to a member state's gross domestic product. Expectations following the ECB policymakers’ upcoming meeting on September 8th are mixed: some expect the ECB to extend the run of the QE program beyond March 2017, while others believe it will wait to act until later in the year, in order to have a better understanding of the Brexit fallout.

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On Tuesday, September 6th, Moody’s released its first issue of a new quarterly China Sector Update, "Securitization – China: Sector Update – Q2 2016: Auto ABS and RMBS Credit Quality Remains Firm, NPL Deals Emerge". During H1 2016, the report notes that CLOs showed the largest number of transactions in China's developing securitization market, followed by auto loan ABS and RMBS.

"We believe that our report will help enhance understanding of the Chinese market, which is showing a strong level of development and increasing degree of sophistication," says Marie Lam, a Moody's Associate Managing Director.

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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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