STRUCTURED FINANCE ASSOCIATION for STRUCTURED FINANCE ASSOCIATION
A later version of this report replaces this one, so LegiList's totals use the current version instead. This page shows this version exactly as filed.
Versions of this report
Every filing the register holds for this firm, client and period, oldest first. The most recent one is the version LegiList counts.
| Filing | Filed | Amount | Counted |
|---|---|---|---|
| 3rd Quarter - Report (this page) | Oct 15, 2015 | $120,000 | Replaced |
| 3rd Quarter - Amendment | Oct 19, 2015 | $120,000 | Yes |
What was lobbied
4 issue areas, each in the filer's own words, with who lobbied on it and where.
Financial Institutions/Investments/Securities FIN
During the second quarter 2015, SFIG advocated on the following issues: 1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules. 2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules. 3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding. 5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
| Lobbyist | Covered position, as disclosed |
|---|---|
| MICHAEL P. FLOOD | Office of Management and Budget Program Examiner from 02-2009 to 06-2010 |
Housing HOU
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system. 2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency. 3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac. 4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens. 5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years. 6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.
| Lobbyist | Covered position, as disclosed |
|---|---|
| MICHAEL P. FLOOD | Office of Management and Budget Program Examiner from 02-2009 to 06-2010 |
Commodities (big ticket) CDT
Advocated on SPV's and swaps with the CFTC
| Lobbyist | Covered position, as disclosed |
|---|---|
| MICHAEL P. FLOOD | Office of Management and Budget Program Examiner from 02-2009 to 06/2010 |
Banking BAN
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
| Lobbyist | Covered position, as disclosed |
|---|---|
| MICHAEL P. FLOOD | Office of Management and Budget Program Examiner from 02-2009 to 06/2010 |
Shown as published by the Senate Office of Public Records and the House Clerk under the Lobbying Disclosure Act. The official filing is the record; open it for the full form.