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Reported covered position: Office of Management and Budget Program Examiner from 02-2009 to 06/2010
How to read the money
Income and expense are whole-filing amounts associated with this lobbyist, not personal compensation or an allocated share.
No topic inference: each bill number appears in source LDA issue text assigned to this lobbyist.
Expanding Proven Financing for American Employers Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
During the first quarter 2016, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for H.R. 4166, a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. This includes both the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - SFIG discussed disclosure requirements under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans. 6. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps.
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2016 · second_quarter · Q2
1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital. 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. 3. Mortgage REITs - General issues supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Efforts in support of a 60 day notice to be given to noteholders if an HOA has been granted such superpriority status; also includes advocacy in support of regulators treating loans in private-label securitizations in the same fashion as FHFA treats Agency loans. 5. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 6. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
Source: Senate LDA
Expanding Proven Financing for American Employers Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance date for CLOs related to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015; H.R. 4166, Expanding Proven Financing for American Employers Act, supports a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. 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, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations). 3. General issues concerning an exemption from posting margin for uncleared swaps to be included in final prudential regulations, specifically that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - General issues concerning securitization regulation as it relates to marketplace lending prior to making new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans. 6. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, LCR, NRSRO, Derivatives and Swaps; reform proposals as they relate to securitization and capital markets generally; H.R. 4620, the Preserving Access to CRE Capital Act of 2016.
Preserving Access to CRE Capital Act of 2016
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance date for CLOs related to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015; H.R. 4166, Expanding Proven Financing for American Employers Act, supports a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. 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, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations). 3. General issues concerning an exemption from posting margin for uncleared swaps to be included in final prudential regulations, specifically that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - General issues concerning securitization regulation as it relates to marketplace lending prior to making new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans. 6. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, LCR, NRSRO, Derivatives and Swaps; reform proposals as they relate to securitization and capital markets generally; H.R. 4620, the Preserving Access to CRE Capital Act of 2016.
Expanding Proven Financing for American Employers Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
During the fourth quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for H.R. 4166, a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. This includes both the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book and efforts to create "Simple, Transparent and Comparable" securitizations. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - SFIG submitted a supplemental comment letter to the SEC on outstanding issues remaining in the final Regulation AB II rule. SFIG also discussed Regulation AB II with Congress. 5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
Energy and Water Development and Related Agencies Appropriations Act, 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
During the first quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. SFIG reviewed both the PATH Act and H.R. 5055, Congressmen Carney, Delaney and Himes bills to reform the GSEs 3. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 4. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 5. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 6. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance date for CLOs related to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015; H.R. 4166, Expanding Proven Financing for American Employers Act, supports a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. 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, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations). 3. General issues concerning an exemption from posting margin for uncleared swaps to be included in final prudential regulations, specifically that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - General issues concerning securitization regulation as it relates to marketplace lending prior to making new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans. 6. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, LCR, NRSRO, Derivatives and Swaps; reform proposals as they relate to securitization and capital markets generally; H.R. 4620, the Preserving Access to CRE Capital Act of 2016.
General issues concerning international efforts to establish "high-quality securitization" criteria. 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 Step-in risk).
Filing targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2016 · first_quarter · Q1
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. 2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. While the Industry Advisory Group itself is non-policy focused, SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years. 6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market. 7. TRID - SFIG is advocating for clarity on the final "Know Before You Owe" rule to ensure the industry is correctly implementing the rule, while avoiding any unintended consequences.
SFIG advocated for equitable treatment of SPV's for both banks and independent finance companies under the new CFTC margin rules for uncleared swaps.
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria. SFIG is also advocating for equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books. Specifically, SFIG's advocacy efforts have focused on Basel Capital and Liquidity Rules, including international and U.S. implementation. The rules include the Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and Step-in risk
During the first quarter 2016, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for H.R. 4166, a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. This includes both the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - SFIG discussed disclosure requirements under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans. 6. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2015 · fourth_quarter · Q4
During the fourth quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for H.R. 4166, a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. This includes both the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book and efforts to create "Simple, Transparent and Comparable" securitizations. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - SFIG submitted a supplemental comment letter to the SEC on outstanding issues remaining in the final Regulation AB II rule. SFIG also discussed Regulation AB II with Congress. 5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria. SFIG is also advocating for equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books. Specifically, SFIG's advocacy efforts have focused on Basel Capital and Liquidity Rules, including international and U.S. implementation. The rules include the Liquidity Coverage Ratio, the Net Stable Funding Ratio, and the Fundamental Review of the Trading Book
SFIG advocated for equitable treatment of SPV's for both banks and independent finance companies under the new CFTC margin rules for uncleared swaps.
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. 2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. While the Industry Advisory Group itself is non-policy focused, SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years. 6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.
Filing targets: Commodity Futures Trading Commission (CFTC), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2015 · third_quarter · 3A
During the second quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. Regulation AB II - SFIG submitted a comment letter to the SEC on outstanding issues remaining in the final Regulation AB II rule. SFIG also discussed Regulation AB II with Congress. 5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
Advocated on SPV's and swaps
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. 2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. While the Industry Advisory Group itself is non-policy focused, SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years. 6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.
Filing targets: Commodity Futures Trading Commission (CFTC), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2015 · third_quarter · Q3
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. 2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years. 6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.
During the second quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
Advocated on SPV's and swaps with the CFTC
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
Filing targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2015 · second_quarter · Q2
Advocated on SPV's and swaps with the CFTC
During the first quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. SFIG reviewed both the PATH Act and H.R. 5055, Congressmen Carney, Delaney and Himes bills to reform the GSEs 3. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 4. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 5. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 6. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2015 · first_quarter · Q1
During the first quarter 2015, SFIG advocated for changes to the compliance date for collateralized loan obligations to the Volcker rule. SFIG also advocated for reauthorization of the Terrorism Risk Insurance Act
We advocated for GSE reform before Congress, generally. SFIG also advocated for regulatory reforms that may affect the future of housing finance with the FHFA and Treasury, including g-fee adjustments, and the creation of a common securitization platform, as examples.
Advocated on SPV's and swaps with the CFTC
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2014 · fourth_quarter · Q4
SFIG advocated for positions on both the future of the U.S. housing finance system and the future of the private-lable securities (PLS) market with Congress, Treasury and FHFA. We also discussed "eminent domain" as it relates to housing finance. We wanted to "note" that we did not see the FHFA listed in the drop-box below, and therefore listed it here. We also began to analyze the FHFA's g-fee proposal.
SFIG advocated on the implementation of the Dodd-Frank Act with respect to its affect on the securitization and structured finance industry. SFIG discussed its positions with Members of Congress and Federal Regulators. Issues included - but were not limited to - risk retention, collateralized loan obligations, Regulation AB II, Basel implementation (including LCR and NSFR) and the Volcker rule. We note that both the CFPB and FHFA are not on the drop down list, though SFIG has spoken to both as well.
Filing targets: Commodity Futures Trading Commission (CFTC), 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, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2014 · third_quarter · Q3
SFIG advocated for positions on both the future of the U.S. housing finance system and the future of the private-lable securities (PLS) market with Congress, Treasury and FHFA. We wanted to "note" that we did not see the FHFA listed in the drop-box below, and therefore listed it here. We also began to analyze the FHFA's g-fee proposal.
SFIG advocated on the implementation of the Dodd-Frank Act with respect to its affect on the securitization and structured finance industry. SFIG discussed its positions with Members of Congress and Federal Regulators. Issues included - but were not limited to - risk retention, collateralized loan obligations, Regulation AB II, Basel implementation (including LCR and NSFR) and the Volcker rule. We note that both the CFPB and FHFA are not on the drop down list, though SFIG has spoken to both as well.
Filing targets: Commodity Futures Trading Commission (CFTC), 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, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2014 · second_quarter · Q2
SFIG advocated for positions on both the future of the U.S. housing finance system and the future of the private-lable securities (PLS) market with Congress, Treasury and FHFA. We wanted to "note" that we did not see the FHFA listed in the drop-box below, and therefore listed it here. We also began to analyze the FHFA's g-fee proposal.
SFIG advocated on the implementation of the Dodd-Frank Act with respect to its affect on the securitization and structured finance industry. SFIG discussed its positions with Members of Congress and Federal Regulators. Issues included - but were not limited to - risk retention, collateralized loan obligations, Regulation AB II, Basel implementation (including LCR and NSFR) and the Volcker rule. We note that both the CFPB and FHFA are not on the drop down list, though SFIG has spoken to both as well.
Filing targets: Commodity Futures Trading Commission (CFTC), 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, White House Office
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2014 · first_quarter · Q1
SFIG advocated for positions on both the future of the U.S. housing finance system and the future of the private-lable securities (PLS) market with Congress, Treasury and FHFA. We wanted to "note" that we did not see the FHFA listed in the drop-box below, and therefore listed it here.
SFIG lobbied on the implementation of the Dodd-Frank Act with respect to its affect on the structured finance industry. SFPIG spoke to both Congress and federal regulators. Issues included - but were not limited to - risk retention, collateralized loan obligations, Regulation AB II, Basel implementation (including the liquidity coverage ratio) and the Volcker rule. We note that both the CFPB and FHFA are not on the drop down list, though SFIG has spoken to both as well.
Filing targets: Commodity Futures Trading Commission (CFTC), 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
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2014 · first_quarter · RR
SFIG will advocate on all issues that affect the securitization and structured finance industry. This can include - but may not be limited to - asset classes including RMBS, CMBS, Auto ABS, Credit Card ABS, CLOs, ABCP, Student Loans, Equipment ABS, and Esoteric ABS (like solar or rental securitizations). These areas will likely be affected by Dodd-Frank implementation, housing finance reform and general financial services reform efforts.
SFIG will advocate on all issues that affect the securitization and structured finance industry. This can include - but may not be limited to - asset classes including RMBS, CMBS, Auto ABS, Credit Card ABS, CLOs, ABCP, Student Loans, Equipment ABS, and Esoteric ABS (like solar or rental securitizations). These areas will likely be affected by Dodd-Frank implementation, housing finance reform and general financial services reform efforts.
We advocated for GSE reform before Congress, generally. SFIG also advocated for regulatory reforms that may affect the future of housing finance with the FHFA and Treasury, including g-fee adjustments, and the creation of a common securitization platform, as examples.
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
Filing targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
Filing targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office
SFIG will advocate on all issues that affect the securitization and structured finance industry. This can include - but may not be limited to - asset classes including RMBS, CMBS, Auto ABS, Credit Card ABS, CLOs, ABCP, Student Loans, Equipment ABS, and Esoteric ABS (like solar or rental securitizations). These areas will likely be affected by Dodd-Frank implementation, housing finance reform and general financial services reform efforts.
SFIG will advocate on all issues that affect the securitization and structured finance industry. This can include - but may not be limited to - asset classes including RMBS, CMBS, Auto ABS, Credit Card ABS, CLOs, ABCP, Student Loans, Equipment ABS, and Esoteric ABS (like solar or rental securitizations). These areas will likely be affected by Dodd-Frank implementation, housing finance reform and general financial services reform efforts.
SFIG will advocate on all issues that affect the securitization and structured finance industry. This can include - but may not be limited to - asset classes including RMBS, CMBS, Auto ABS, Credit Card ABS, CLOs, ABCP, Student Loans, Equipment ABS, and Esoteric ABS (like solar or rental securitizations). These areas will likely be affected by Dodd-Frank implementation, housing finance reform and general financial services reform efforts.