STRUCTURED FINANCE ASSOCIATION for STRUCTURED FINANCE ASSOCIATION

Banking BAN

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).

Contacted: Federal Reserve System; HOUSE OF REPRESENTATIVES; Federal Deposit Insurance Corporation (FDIC); Government Accountability Office (GAO); SENATE; White House Office; Internal Revenue Service (IRS); Securities & Exchange Commission (SEC); Treasury, Dept of; Consumer Financial Protection Bureau (CFPB); Office of the Comptroller of the Currency (OCC); Federal Housing Finance Agency (FHFA)

Financial Institutions/Investments/Securities FIN

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.

Contacted: Securities & Exchange Commission (SEC); Internal Revenue Service (IRS); Federal Housing Finance Agency (FHFA); Government Accountability Office (GAO); HOUSE OF REPRESENTATIVES; White House Office; Federal Deposit Insurance Corporation (FDIC); Federal Reserve System; SENATE; Consumer Financial Protection Bureau (CFPB); Treasury, Dept of; Office of the Comptroller of the Currency (OCC)

Bills named: H.R. 4166 (114th), H.R. 5983 (114th)

Housing HOU

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.

Contacted: Consumer Financial Protection Bureau (CFPB); Office of the Comptroller of the Currency (OCC); Treasury, Dept of; White House Office; Federal Reserve System; Federal Housing Finance Agency (FHFA); Government Accountability Office (GAO); HOUSE OF REPRESENTATIVES; SENATE; Securities & Exchange Commission (SEC); Federal Deposit Insurance Corporation (FDIC); Internal Revenue Service (IRS)

Taxation/Internal Revenue Code TAX

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.

Contacted: Federal Reserve System; White House Office; Securities & Exchange Commission (SEC); Office of the Comptroller of the Currency (OCC); Consumer Financial Protection Bureau (CFPB); Government Accountability Office (GAO); SENATE; HOUSE OF REPRESENTATIVES; Treasury, Dept of; Federal Deposit Insurance Corporation (FDIC); Internal Revenue Service (IRS); Federal Housing Finance Agency (FHFA)