STRUCTURED FINANCE ASSOCIATION for STRUCTURED FINANCE ASSOCIATION
What was lobbied
3 issue areas, each in the filer's own words, with who lobbied on it and where.
Banking BAN
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).
| Lobbyist | Covered position, as disclosed |
|---|---|
| THOMAS MCCROCKLIN | — |
Financial Institutions/Investments/Securities FIN
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.
| Lobbyist | Covered position, as disclosed |
|---|---|
| THOMAS MCCROCKLIN New | — |
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 - 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.
| Lobbyist | Covered position, as disclosed |
|---|---|
| THOMAS MCCROCKLIN New | — |
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.