September 9, 2015 Newsletter
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September 9, 2015

Industry Jobs

SFIG Calendar



Advocacy Outlook

Industry News Highlights


SFIG and IMN are pleased to announce Mohamed El-Erian and Michael Piwowar as Keynote Speakers at ABS Vegas 2016.


Mohamed A. El-Erian
Chief Economic Advisor at Allianz
Chair of President Obama's Global Development Council
Former CEO and co-CIO of PIMCO

Mohamed A. El-Erian is Chief Economic Advisor at Allianz, the corporate parent of PIMCO where he formerly served as chief executive and co-chief investment officer. He chairs President Obama's Global Development Council, is a columnist for Bloomberg View and a contributing editor at the Financial Times. Dr. El-Erian first joined PIMCO in 1999 and was a senior member of PIMCO's portfolio management and investment strategy group. He rejoined the company at the end of 2007 after serving for two years as president and CEO of Harvard Management Company, the entity that manages Harvard's endowment and related accounts. Before coming to PIMCO, Dr. El-Erian was a managing director at Salomon Smith Barney/Citigroup in London and before that, he spent 15 years at the International Monetary Fund in Washington, D.C.
View Full Bio

Michael S. Piwowar
U.S. Securities and Exchange Commission (SEC)

Michael S. Piwowar was appointed by President Barack Obama to the U.S. Securities and Exchange Commission (SEC) and was sworn in on August 15, 2013.

Most recently, Dr. Piwowar was the Republican chief economist for the U.S. Senate Committee on Banking, Housing, and Urban Affairs under Senators Mike Crapo (R-ID) and Richard Shelby (R-AL). He was the lead Republican economist on the four SEC-related titles of the Dodd-Frank Act and the JOBS Act. Dr. Piwowar also worked on a number of important SEC-related oversight issues under the jurisdiction of the Committee, such as securities, over-the-counter derivatives, investor protection, market structure, and capital formation.
View Full Bio


SFIG members receive special discounted rates off registration and sponsorship:
For sponsorship information, please contact Christopher Keeping
at +1 212.901.0533 or

Speaking at ABS Vegas 2016:

Agenda and Speaker Nomination Process to be Announced Soon

Reserve your place today!


Last Wednesday, September 2nd, Moody’s Investors Service published a new report that illustrates the application of its proposed new assumptions for rating student loan ABS backed by loans made under the Federal Family Education Loan Program ("FFELP"). Moody’s also announced that it has extended until October 30, 2015 the comment period on its Request for Comment ("RFC") regarding the proposed changes to rating these securities.

“This extension will provide additional time for market participants to review this illustration along with other aspects of our RFC,” says Moody’s Managing Director Debash Chatterjee. “The newly published document provides additional clarity and transparency on how we plan to apply the proposed assumptions by providing an example of a sample loan pool.”

Moody's invites market participants to provide feedback on the RFC by submitting their comments here.

After considering responses to this RFC, Moody’s will finalize its revised approach to rating securities backed by FFELP student loans, publish its updated methodology, resolve the ratings of the securities put on review in April and June and take rating actions on any other securities impacted by the revised methodology.

SFIG's Student Loan Committee is working on a response to these proposed changes and submitted an extension request on August 14th. We appreciate the extension of the comment deadline as it provides a better opportunity to provide a thoughtful and meaningful response to the RFC.

If you are interested in joining our Student Loan Committee, please contact


SFIG will not be publishing a newsletter next week. The SFIG staff looks forward to seeing many of you in Miami at the ABS East 2015 conference from September 16th-18th. Newsletter publications will resume on September 23rd.


Current open positions at SFIG include:

  1. Director of Mortgage Policy: will lead all initiatives related to mortgage-backed securitization. This is a high profile position within the SFIG leadership team working directly with executive management, the Board of Directors, Committee Chairs and key members of SFIG’s membership. Additional information on the position, as well as a link to the application, is available here.

  2. 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 10, 2015
10:00 a.m. – 11:00 a.m. (ET)
THURSDAY, September 10, 2015
12:00 p.m. - 5:00 p.m. (ET)
THURSDAY, September 10, 2015
2:00 p.m. - 3:00 p.m. (ET)
FRIDAY, September 11, 2015
8:30 a.m. – 9:30 a.m. (ET)
FRIDAY, September 11, 2015
11:00 a.m. – 12:00 p.m. (ET)
FRIDAY, September 11, 2015
2:00 p.m. – 3:00 p.m. (ET)
TUESDAY, September 15, 2015
11:00 a.m. – 12:00 p.m. (ET)
WEDNESDAY, September 16, 2015 – FRIDAY, September 18, 2015
The Fontainebleau
Miami Beach, FL
Registration available here
  • Richard Johns will speak on the “High Quality Securitizations” panel
  • Sairah Burki will speak on the “Assessing The Impact of Regulatory Reform on ABS Market Liquidity” panel
  • Michael Flood will speak on the “Single Asset/Single Borrower CMBS” panel
  • SFIG will also sponsor a “Women in Securitization” panel

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


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 that they will be extending the deadline for comments 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. Following the successful SFIG/IMN Private Label RMBS Symposium, the task force will continue 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 afternoon. 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. We 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


According to a recent article in The Guardian, European Central Bank (“ECB”) President Mario Draghi is ready to bolster the eurozone with more stimulus following the eurozone’s faltering economy, particularly given worries about China.

As previously reported by SFIG, the ECB launched its approximately $1.2 trillion ABS purchase program on November 21, 2014 in an effort to encourage banks to lend more and revive the economy. Quantitative easing (“QE”) began this past March and aims to inject $66.8 billion into the banking system each month. QE is due to end in September 2016, but asset purchases can run for longer if necessary, Draghi said.

Howard Archer, Chief European Economist at IHS Global Insight, said Draghi is preparing the ground for a further stimulus. “The door is now clearly wide open to the ECB stepping up its near-term pace of QE and/or increasing its overall size and duration,” Archer said. “Whether the ECB steps through that door will clearly depend on whether eurozone growth continues to struggle and inflation prospects deteriorate further.”


With Congress’ return from summer recess yesterday, September 8th, lawmakers are expected to begin consideration of several matters of interest to the securitization industry, including housing finance reform and Senator Richard Shelby’s (R-AL) regulatory relief bill. Senator Shelby’s bill, the Financial Regulatory Improvement Act of 2015, would revise several portions of the Dodd-Frank Act and includes language on a Safe Harbor for qualified mortgages held in portfolio, the development of a Common Securitization Platform and other market infrastructure, and credit risk sharing. The bill was approved by the Senate Appropriations Committee in July as part of a broader funding bill but has faced opposition from Senate Democrats. According to an article by American Banker, measures from the banking reform package could make their way into a larger omnibus deal that would be used “to fund the government, raise the debt limit or continue the country’s transportation program.”

American Banker also describes how a proposed salary increase for the chief executives of Fannie Mae and Freddie Mac (“GSEs”) have reignited the debate around housing finance reform. Federal Housing Finance Agency Director Mel Watt proposed raising the executives’ annual compensation from $600,000 to nearly $4 million, leading to backlash from Congress and the Treasury Department. According to American Banker, “It’s possible that lawmakers could use the provision to introduce additional, but still-narrow housing finance measures to spur risk-sharing at the GSEs and move more private capital into the market.” However, “roader efforts to unwind or even recapitalize Fannie Mae and Freddie Mac are not expected to gain political traction this year in what is expected to already be a very busy congressional session.”

The Volcker Rule banning proprietary trading may make it difficult for banks to hold CMBS during a volatile market, according to an article in Reuters. Under the new regulations, regulators can penalize underwriting banks who do not account for reasonable expected near-term demand (“RENTD”). Scott Cammarn of Cadwalader, Wickersham & Taft told Reuters, “You can’t take an allotment of bonds as an underwriting position unless down the line you believe you have the ability to place it in a reasonable amount of time under Volcker.”

September is expected to be a volatile month, and deals launching in September could leave banks facing losses. According to the article, “[v]olatility in broader markets has created havoc for rates, sending senior 10-year CMBS Triple A spreads gapping out 33bp in the last 14 weeks and 80bp on Triple B minus slices of debt.” The regulations will also impact the playing field for investors and issuers, as underwriters will have less control on where bonds price. If the new rules are not followed by the industry, regulators will be able to penalize banks, although the potential RENTD penalties have yet to be specified.

Investor appetite for riskier U.S. residential mortgages has picked up although banks are still wary of lending to risky homebuyers, according to an article in the Financial Times. As stated in the article, “ssuance of residential mortgage-backed securities that do not carry the guarantee of government agencies such as Fannie Mae and Freddie Mac has since dried up to less than $10 billion for the whole of 2014, from more than $500 billion a year pre-crisis.”

Following the financial crisis, regulators introduced new rules to raise lending standards. As stated in the article, “[o]ne way for banks and other lenders to satisfy these new rules is by issuing a qualified mortgage (QM), for which applicants must meet a total monthly debt-to-income ratio of 43 percent or less.” While banks continue to operate in a restrictive mode, non-bank lenders could begin to meet investor demand in an effort to revive the “non-prime” market. “The non QM market is currently in its infancy, and we think it will provide good opportunities over the next year for originators and investors, but it is a chicken and egg situation right now — it’s unclear how big it will be,” said Jamshed Engineer of Axonic Capital.


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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