Lobbying Filing Details

Activity 1

Banking

1. General issues concerning international efforts to establish "high-quality securitization" criteria.

2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations).

Lobbyists (1)

• LESLIE J. SACK

Government Entities (9)

• SENATE
• HOUSE OF REPRESENTATIVES
• Housing & Urban Development, Dept of (HUD)
• Treasury, Dept of
• Commodity Futures Trading Commission (CFTC)
• ... and 4 more

Activity 2

Financial Institutions/Investments/Securities

1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs).

2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans.

3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFIG recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization.

4. 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). SFIG was selected to co-chair the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition.

5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions.

Lobbyists (1)

• LESLIE J. SACK

Government Entities (9)

• SENATE
• HOUSE OF REPRESENTATIVES
• Housing & Urban Development, Dept of (HUD)
• Treasury, Dept of
• Commodity Futures Trading Commission (CFTC)
• ... and 4 more

Activity 3

Housing

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). Review and provide feedback on draft bipartisan bill to reform Fannie Mae and Freddie Mac.

2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a uniform mortgage backed security (UMBS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs.

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. Support of a free-market, competition-based approach to the GSE's use of alternative credit models.

5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.

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, including lobbying and advocacy around proposed legislative fixes to the FCA.

9. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II as it relates to RMBS issuance offerings.

Lobbyists (1)

• LESLIE J. SACK

Government Entities (9)

• SENATE
• HOUSE OF REPRESENTATIVES
• Housing & Urban Development, Dept of (HUD)
• Treasury, Dept of
• Commodity Futures Trading Commission (CFTC)
• ... and 4 more