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.
An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018.
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018.
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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
2018 · first_quarter · 1A
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
Source: Senate LDA
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
Financial CHOICE Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Financial CHOICE Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Economic Growth, Regulatory Relief, and Consumer Protection Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
Economic Growth, Regulatory Relief, and Consumer Protection Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018.
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
Financial CHOICE Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs, specifically, supporting 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. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; and reform proposals as they relate to securitization and capital markets generally.
Financial CHOICE Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
Financial CHOICE Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally. 5. S.1642 (Protecting Consumer Access to Credit Act of 2017) - specifically, the effect on the secondary loan market and, by extension, securitizations.
Fannie and Freddie Open Records Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. GSE FOIA Applicability - (H.R.298/H.R.1694), The Fannie and Freddie Open Records Act of 2017, specifically issues concerning scope of FOIA. 7. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 8. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Fannie Mae and Freddie Mac Transparency Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. GSE FOIA Applicability - (H.R.298/H.R.1694), The Fannie and Freddie Open Records Act of 2017, specifically issues concerning scope of FOIA. 7. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 8. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 7. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT). 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 7. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
Credit Score Competition Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. GSE FOIA Applicability - (H.R.298/H.R.1694), The Fannie and Freddie Open Records Act of 2017, specifically issues concerning scope of FOIA. 7. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 8. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally. 5. S.1642 (Protecting Consumer Access to Credit Act of 2017) - specifically, the effect on the secondary loan market and, by extension, securitizations.
Protecting Consumers' Access to Credit Act of 2017
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
Economic Growth, Regulatory Relief, and Consumer Protection Act
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
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.
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 requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
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 requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
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.
Financial CHOICE Act of 2016
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
Financial CHOICE Act of 2016
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
Taxpayer Protections and Market Access for Mortgage Finance Act of 2016
Client: STRUCTURED FINANCE ASSOCIATION · Firm: STRUCTURED FINANCE ASSOCIATION
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; discussions/proposals related to credit risk transfer (CRT) 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 - H.R. 6487, The Taxpayer Protection and Market Access for Mortgage Finance Act, specifically provisions supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
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)
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2018 · first_quarter · Q1
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
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)
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations. 6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York 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). Richard Johns is a co-chair of the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition. 7. Asset-backed securities (ABS) disclosure: Published best practice recommendations, developed by industry participants, for the disclosure of asset data and pool performance for ABS collateralized by unsecured consumer loans. Shared and discussed report with US Department of the Treasury in connection with their forthcoming report on financial technology.
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2017 · fourth_quarter · Q4
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
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; discussions/proposals related to credit risk transfer (CRT). 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. 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). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.
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)
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization. 5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
Filing targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2017 · third_quarter · Q3
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).
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs. 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, 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). 3. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally. 5. S.1642 (Protecting Consumer Access to Credit Act of 2017) - specifically, the effect on the secondary loan market and, by extension, securitizations.
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; discussions/proposals related to credit risk transfer (CRT). 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 7. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
Filing targets: Commodity Futures Trading Commission (CFTC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2017 · second_quarter · Q2
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs, specifically, supporting 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. 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. 4. 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; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule, arbitration clauses, lead regulator concept, and "valid when made" loan provisions; and reform proposals as they relate to securitization and capital markets generally.
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 7. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
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 Step-in risk).
Filing targets: Commodity Futures Trading Commission (CFTC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2017 · first_quarter · Q1
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 Step-in risk).
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs, specifically, supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally, and uncleared swap margin rules. 6. Proposed rulemaking concerning single counterparty credit limits.
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2016 · fourth_quarter · Q4
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
STRUCTURED FINANCE ASSOCIATION via STRUCTURED FINANCE ASSOCIATION
2016 · third_quarter · Q3
Proposed regulations under Section 385 of the Internal Revenue Code of 1986, as amended on April 4, 2016, specifically, the unintended consequences/impact on the securitization market.
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting 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. 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. 4. 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. 5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts. 6. Proposed rulemaking concerning single counterparty credit limits.
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.
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; discussions/proposals related to credit risk transfer (CRT) 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 - Proposals supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. GSE FOIA Applicability - (H.R.298/H.R.1694), The Fannie and Freddie Open Records Act of 2017, specifically issues concerning scope of FOIA. 7. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 8. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
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
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; discussions/proposals related to credit risk transfer (CRT) 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 - H.R. 6487, The Taxpayer Protection and Market Access for Mortgage Finance Act, specifically provisions supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
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, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
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).
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; discussions/proposals related to credit risk transfer (CRT) 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. 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). 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
Filing targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
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.
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