A joint resolution disapproving the rule submitted by the Financial Crimes Enforcement Network relating to "Anti-Money Laundering Regulations for Residential Real Estate Transfers".

Consumer Financial Protection Bureau Withdrawal of Bureau Guidance, Interpretive Rules, Policy Statements, and Advisory Opinions; 12 CFR Chapter X; 90 Fed. Reg. 20084 (May 12, 2025) [withdrawing numerous CFPB guidance documents, including CFPB Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations. Department of the Treasury Financial Crimes Enforcement Network Final Rule on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Document No. 2024-19198; RIN 1506-AB54, 89 Fed. Reg. 70258 (August 29, 2024). H.J.Res. 55, S.J.Res. 15, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Crimes Enforcement Network relating to "Anti-Money Laundering Regulations for Residential Real Estate Transfers". H.R. 3213, the Restoring Court Authority Over Litigation Act. Support favorable assessment of United States laws, regulations, and efforts to combat money laundering and terrorist financing and oppose any new proposed regulations on US lawyers in upcoming Financial Action Task Force 2026 Mutual Evaluation Report for the US.

Client expense: $250,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

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.

Consumer Financial Protection Bureau Withdrawal of Bureau Guidance, Interpretive Rules, Policy Statements, and Advisory Opinions; 12 CFR Chapter X; 90 Fed. Reg. 20084 (May 12, 2025) [withdrawing numerous CFPB guidance documents, including CFPB Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations. Department of the Treasury Financial Crimes Enforcement Network Final Rule on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Document No. 2024-19198; RIN 1506-AB54, 89 Fed. Reg. 70258 (August 29, 2024). H.J.Res. 55, S.J.Res. 15, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Crimes Enforcement Network relating to "Anti-Money Laundering Regulations for Residential Real Estate Transfers". H.R. 3213, the Restoring Court Authority Over Litigation Act.

Client expense: $220,000 · Firm income: Not reported

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.

Consumer Financial Protection Bureau Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations. Department of the Treasury Financial Crimes Enforcement Network Final Rule on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Document No. 2024-19198; RIN 1506-AB54, 89 Fed. Reg. 70258 (August 29, 2024). H.J.Res. 55, S.J.Res. 15, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Crimes Enforcement Network relating to "Anti-Money Laundering Regulations for Residential Real Estate Transfers". H.R. 3213, the Restoring Court Authority Over Litigation Act.

Client expense: $180,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

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.

Consumer Financial Protection Bureau Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations. Department of the Treasury Financial Crimes Enforcement Network Final Rule on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Document No. 2024-19198; RIN 1506-AB54, 89 Fed. Reg. 70258 (August 29, 2024). H.J.Res. 55, S.J.Res. 15, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Crimes Enforcement Network relating to "Anti-Money Laundering Regulations for Residential Real Estate Transfers". H.R. 3213, the Restoring Court Authority Over Litigation Act.

Client expense: $280,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

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.

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.