Lobbying Filing Details

Total Spending

$120,000

Activities

4

Lobbyists

1

Gov't Entities

44

Filing Information
Filing UUID:
3ff27bc4-cb0c-46bc-9898-9b4675875126
Type:
Q4 - 4th Quarter - Report
Period:
2015 - 4th Quarter (Oct 1 - Dec 31)
Date Posted:
January 21, 2016 at 5:49 PM
Income:
$0
Expenses:
$120,000
Expense Method:
Method B - Reporting amounts under section 6033(b)(8) of the Internal Revenue Code
Document URL:
View Submission
Quick Info
  • Document Type: text/html
  • Posted By: Michael P. Flood, Jr.
Registrant
STRUCTURED FINANCE ASSOCIATION

Financial services trade assn. focused on structured finance & securitization issues.

Washington, District of Columbia
Client
STRUCTURED FINANCE ASSOCIATION
District of Columbia, United States of America
Lobbying Activities (4)
Activity 1
Banking

SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.

SFIG is also advocating for equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books. Specifically, SFIG's advocacy efforts have focused on Basel Capital and Liquidity Rules, including international and U.S. implementation. The rules include the Liquidity Coverage Ratio, the Net Stable Funding Ratio, and the Fundamental Review of the Trading Book

Lobbyists (1)
  • MR. MICHAEL P. FLOOD JR
Government Entities (11)
  • SENATE
  • HOUSE OF REPRESENTATIVES
  • White House Office
  • Treasury, Dept of
  • Commodity Futures Trading Commission (CFTC)
  • ... and 6 more
Activity 2
Commodities (big ticket)

SFIG advocated for equitable treatment of SPV's for both banks and independent finance companies under the new CFTC margin rules for uncleared swaps.

Lobbyists (1)
  • MR. MICHAEL P. FLOOD JR
Government Entities (11)
  • SENATE
  • HOUSE OF REPRESENTATIVES
  • White House Office
  • Treasury, Dept of
  • Commodity Futures Trading Commission (CFTC)
  • ... and 6 more
Activity 3
Financial Institutions/Investments/Securities

During the fourth quarter 2015, SFIG advocated on the following issues:

1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for H.R. 4166, a qualified CLO retention regime as an alternative to the final risk-retention rules.

2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. This includes both the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book and efforts to create "Simple, Transparent and Comparable" securitizations.

3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received.

4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding.

5. Regulation AB II - SFIG submitted a supplemental comment letter to the SEC on outstanding issues remaining in the final Regulation AB II rule. SFIG also discussed Regulation AB II with Congress.

5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps

Lobbyists (1)
  • MR. MICHAEL P. FLOOD JR
Government Entities (11)
  • SENATE
  • HOUSE OF REPRESENTATIVES
  • White House Office
  • Treasury, Dept of
  • Commodity Futures Trading Commission (CFTC)
  • ... and 6 more
Activity 4
Housing

1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system.

2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. While the Industry Advisory Group itself is non-policy focused, SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency.

3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac.

4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens.

5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years.

6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.

Lobbyists (1)
  • MR. MICHAEL P. FLOOD JR
Government Entities (11)
  • SENATE
  • HOUSE OF REPRESENTATIVES
  • White House Office
  • Treasury, Dept of
  • Commodity Futures Trading Commission (CFTC)
  • ... and 6 more

Source: LDA.gov, data retrieved November 9, 2026. FilingExplorer is not affiliated with LDA.gov; the Senate Office of Public Records cannot vouch for data or analyses derived from these records after retrieval.