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Adjustable Interest Rate (LIBOR) Act of 2021
Legislative Progress
Momentum (last 30 days)
0
score
0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
90pct
224d open
vs 9,698 other HR bills in the 117th — cohort avg 63d
Adjustable Interest Rate (LIBOR) Act of 2021 This bill provides for the transition of certain financial contracts away from the London Interbank Offered Rate (LIBOR), a reference interest rate based upon the lending terms certain banks offer to each other for various lengths of time. LIBOR is set to be retired in 2023. Various financial contracts reference LIBOR as a benchmark for prevailing interest rates and use LIBOR in calculating certain payments or obligations. In the event a contract referencing LIBOR does not have a fallback or replacement rate provision in effect when LIBOR is retired, or a replacement rate is not selected by a determining person as defined by the bill, the bill provides for a transition to a replacement rate selected by the Board of Governors of the Federal Reserve System. The bill also provides for conforming changes to these contracts, the continuity and enforceability of these contracts, and protections against liability as a result of such a transition.
Yes
415
No
9
Present
0
Not Voting
9
Party Breakdown
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Filing registrants (38)
Committee on Banking, Housing, and Urban Affairs. Hearings held.
Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Motion to reconsider laid on the table Agreed to without objection.
On motion to suspend the rules and pass the bill, as amended Agreed to by the Yeas and Nays: (2/3 required): 415 - 9 (Roll no. 407). (text: CR H7479-7481)
HousePassed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by the Yeas and Nays: (2/3 required): 415 - 9 (Roll no. 407).(text: CR H7479-7481)
HouseConsidered as unfinished business. (consideration: CR H7529-7530)
At the conclusion of debate, the Yeas and Nays were demanded and ordered. Pursuant to the provisions of clause 8, rule XX, the Chair announced that further proceedings on the motion would be postponed.
DEBATE - The House proceeded with forty minutes of debate on H.R. 4616.
Considered under suspension of the rules. (consideration: CR H7479-7486)
Bills with similar content found using semantic analysis.
Sources: Congress.gov · House Clerk roll-call votes
| house |
| On Motion to Suspend the Rules and Pass, as Amended |
Passed |
| December 8, 2021 |
2026 · third_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $325,946 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2026 · third_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2026 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2026 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2026 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Mr. Sherman moved to suspend the rules and pass the bill, as amended.
Placed on the Union Calendar, Calendar No. 147.
Committee on Education and Labor discharged.
Committee on Education and Labor discharged.
Committee on Ways and Means discharged.
Committee on Ways and Means discharged.
Reported (Amended) by the Committee on Financial Services. H. Rept. 117-206, Part I.
Congress.gov source codes: 5000, H12200
Ordered to be Reported in the Nature of a Substitute (Amended) by Voice Vote.
Committee Consideration and Mark-up Session Held.
Committee Consideration and Mark-up Session Held.
Referred to the Committee on Financial Services, and in addition to the Committees on Ways and Means, and Education and Labor, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Introduced in House
Congress.gov source codes: 1000, Intro-H
| House |
| Discharged from |
| December 8, 2021 |
| Financial Services Committee | House | Reported by | December 8, 2021 |
| Financial Services Committee | House | Markup by | July 29, 2021 |
| Financial Services Committee | House | Markup by | July 28, 2021 |
| Financial Services Committee | House | Referred to | July 22, 2021 |
| Education and the Workforce Committee | House | Referred to | July 22, 2021 |
| Ways and Means Committee | House | Referred to | July 22, 2021 |
| July 22, 2021 |
Client expense: $325,946 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $325,946 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $309,861 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $309,861 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2026 · second_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $309,861 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2026 · first_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $387,651 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2026 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $387,651 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2026 · first_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $387,651 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2025 · fourth_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $353,844 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · fourth_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $353,844 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2025 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $353,844 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · third_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $347,609 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · third_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $347,609 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2025 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $347,609 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $314,666 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · second_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $314,666 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2025 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $314,666 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · first_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $338,881 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $338,881 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · first_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $338,881 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2024 · fourth_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $242,716 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2024 · fourth_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $242,716 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $242,716 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $253,750 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · third_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $253,750 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · third_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $253,750 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2024 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $256,928 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $256,928 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · second_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $256,928 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2024 · first_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $258,149 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2024 · first_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $258,149 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $258,149 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · fourth_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $267,129 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · fourth_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $267,129 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2023 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $267,129 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · third_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $239,692 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $239,692 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · third_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $239,692 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2023 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $203,106 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · second_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $203,106 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2023 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $203,106 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · first_quarter · Financial Institutions/Investments/Securities
Securitization issues, rating agency issues, ESG Environmental, Social and Governance disclosures to investors, and issues related to LIBOR. H.R. 1187, the ESG Disclosure Simplification Act; H.R. 2570, the Climate Risk Disclosure Act; H.R. 1549, the Addressing Climate Financial Risk Act; H.R. 3571, the Climate Change Financial Risk Act of 2021; and H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021. Issues related to climate change. Expiration of SEC no action letter on 144a private debt offerings; H.R. 6632, regarding certain regulatory requirements for quotations of fixed-income securities. SEC Rule 192 proposal
Client expense: Not reported · Firm income: $50,000
Government targets: Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)
2023 · first_quarter · Financial Institutions/Investments/Securities
Securitization issues, rating agency issues, ESG Environmental, Social and Governance disclosures to investors, and issues related to LIBOR. H.R. 1187, the ESG Disclosure Simplification Act; H.R. 2570, the Climate Risk Disclosure Act; H.R. 1549, the Addressing Climate Financial Risk Act; H.R. 3571, the Climate Change Financial Risk Act of 2021; and H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021. Issues related to climate change. Expiration of SEC no action letter on 144a private debt offerings; H.R. 6632, regarding certain regulatory requirements for quotations of fixed-income securities. SEC Rule 192 proposal
Client expense: $270,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2023 · first_quarter · Taxation/Internal Revenue Code
1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements. 2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs. 3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $156,053 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2023 · first_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $156,053 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $156,053 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Issues related to H.R.328 (The Wall Street Tax Act of 2021) Issues related to LIBOR and H.R.4616 (Adjustable Interest Rate (LIBOR) Act of 2021) Issues related to self-regulatory organization (SRO) reform
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · fourth_quarter · Banking
3/8 Senate Banking Hearing: Examining Mandatory Arbitration in Financial Service Products H.R. 963 Forced Arbitration Injustice Repeal (FAIR) Act of 2022 3/31 House Financial Services Subcommittee on Consumer Protection and Financial Institutions Hearing- The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions House/Senate Hearing: Annual Oversight of the Nations Largest Banks S.4674 - Credit Card Competition Act of 2022 H.R.8874 - Credit Card Competition Act of 2022 Issues related to Zelle payment platform and changes to Regulation E House Financial Services Discussion Draft: Stable Coin Legislation Issues related to Biden Administration Student Loan Forgiveness Plan Issues related to changing UDAAP legislation Issues related to banning arbitration agreements H.R.7900 - National Defense Authorization Act for Fiscal Year 2023 H.R. 8152 - American Data Privacy and Protection Act H.R. ____ - Protecting Consumers From Payment Scams Act Issues related to Section 1034 of Dodd-Frank Act Issues related to CFPB Credit Card Late Fees and Late Payments H.R.7412 - Transparency in CFPB Cost-Benefit Analysis Act H.R.6802 - Preventing Racial Profiling in Lending Act H.R.6732 - Small LENDER Act H.R.7352 - PPP and Bank Fraud Enforcement Harmonization Act of 2022 Issues related to 7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. Pub. Law 117-169 Build Back Better Act - Implementation of IRS Reporting Bank Account Information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act Issues related to FDIC Director appointment House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to fair lending and fair banking Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws CFPB Section 1071 rulemaking Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to bank fees, including overdraft fees and credit card late fees. Issues related to COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to credit card network interchange fees. Issues related to U.S. Postal Service banking services. Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to AML-BSA Reform Issues related to FinCEN CDD Rule Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter Terrorism & Illicit Finance Act S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Electronic Fund Transfer Act, regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to Section 1033 of Dodd-Frank Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Fintech oversight Issues related to Buy Now Pay Later Issues related to CFPB Credit Card Safe Harbor fee Issues related to Section 1071 Small Business Data Collection Issues related to UDAAP exam manual changes
Client expense: $1,290,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Education, Dept of, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III Implementation of S. 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act. Issue: Implementation and regulatory reform of the financial services industry. Implementation of H.R. 748 - the Coronavirus Aid, Relief, and Economic Security (CARES) Act. This bill responds to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. Issue: CECL, TDR, Remote Online Notarization, SBA loans. H.R. 4866/S. 524 - Federal Insurance Office Abolishment Act of 2021. Issue: FIO reform. H.R. 1996/S. 910 - Secure and Fair Enforcement Banking Act. Issue: Insurance companies working with legitimate marijuana businesses. H.R. 4521 - America COMPETES Act of 2022. This bill addresses U.S. technology and communications, foreign relations and national security, domestic manufacturing, education, trade, and other matters. Issue: Insurance companies working with legitimate marijuana businesses. H.R. 842/S.420 - Protecting Workers Freedom to Organize Act. To amend the National Labor Relations Act, the Labor Management Relations Act, 1947, and the Labor-Management Reporting and Disclosure Act of 1959. Issue: independent contractor status. H.R. 1523/S. 526 - Modern Worker Empowerment Act. To amend the Fair Labor Standards Act of 1938 to harmonize the definition of employee with the common law. Issue: employee status. H.R. 1277/S. 374 - Improving Corporate Governance Through Diversity Act. To amend the Securities Exchange Act of 1934 to require the submission by issuers of data relating to diversity, and for other purposes. Issue: diversity and inclusion. H.R. 2543 - Federal Reserve Racial and Economic Equity Act. This bill address access to financial services, diversity in various financial institutions and establishments, and other related issues. Issue: diversity and inclusion H.R.4865/S.3198 - Registration for Index-Linked Annuities Act. To direct the SEC to revise any rules necessary to enable issuers of index-linked annuities to use the securities offering forms that are available to other issuers of securities. Issue: index-linked annuities. H.R.3962/S.1625 - Securing and Enabling Commerce Using Remote and Electronic Notarization Act. To authorize and establish minimum standards for electronic and remote notarizations that occur in or affect interstate commerce, to require any Federal court located in a State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce, and to require any State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce or when the notarization was performed under or relates to a public act, record, or judicial proceeding of the State in which the notary public was commissioned. Issue: remote online notarization. H.R. 4350 - National Defense Authorization Act for Fiscal Year 2022. This bill authorizes FY2022 appropriations for military activities and programs of the Department of Defense (e.g., personnel; research, development, test, and evaluation; and procurement of items such as aircraft, missiles, and ammunition). It also prescribes military personnel strengths for FY2022. Issue: remote online notarization and cannabis banking. H.R. 4616/S. 3779 - To deem certain references to the London Interbank Offered Rate (LIBOR) as referring to a replacement benchmark rate in the case of LIBOR no longer being available. Issue: LIBOR. H.R. 2471 - Consolidated Appropriations Act, 2022. This bill provides appropriations to federal agencies for the remainder of FY2022, provides supplemental appropriations for activities to support Ukraine, and modifies or establishes various programs that address a wide range of policy areas. Issue: LIBOR. H.R. 1187 - the ESG Disclosure Simplification Act. This legislation requires the disclosure of key environmental, social, and governance metrics to shareholders of public companies. Issue: ESG. S. 3715 - Electronic Signatures in Global and National Commerce Act. To amend the Electronic Signatures in Global and National Commerce Act to accommodate emerging technologies. Issue: electronic signatures. S.Con.Res.14 - Concurrent Resolution on the Budget, FY2022. The budget resolution calls for the $3.5 trillion in long-term investments to be fully offset by a combination of new tax revenues, health care savings, and long-term economic growth. In addition, the agreement would prohibit new taxes on families making less than $400,000 per year, and on small businesses and family farms. Issue: unemployment insurance. S. 4591 Cannabis Administration and Opportunity Act. This legislation aims to end the decades of harm inflicted on communities of color by removing cannabis from the federal list of controlled substances and empowering states to implement their own cannabis laws. H.R. 3294/S. 1945 - IGNITE HBCU Excellence Act. This bill establishes a grant program to support long-term improvements of historically Black colleges and universities (HBCUs) and graduate programs at HBCUs. Issue: diversity and inclusion. H.R. 2617 Consolidated Appropriations Act, 2023. This legislation makes consolidated appropriations for the fiscal year ending September 30, 2023, and for providing emergency assistance for the situation in Ukraine, and for other purposes. Issue: registration for index linked annuities; cannabis banking. Issue: Cannabis legislation Issue: FHLBank System Issue: Regulation Best Interest Issue: Environmental, Social, and Corporate Governance (ESG). No bill number assigned. Issue: Commercial mortgage-backed security (CMBS) debt. No bill number assigned. Issue: Making Diversity and Inclusion Efforts more Intentional. No bill number assigned. Issue: Unclaimed life insurance products. No bill number assigned. Issue: Covered agreement on prudential measures with respect to the business of insurance and reinsurance. No bill number assigned. Issue: Government Sponsored Enterprises (GSE) reform. No bill number assigned.
Client expense: $1,271,337 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE