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

Financial Institutions/Investments/Securities FIN

1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance date for CLOs related to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015; H.R. 4166, Expanding Proven Financing for American Employers Act, supports 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. General issues concerning an exemption from posting margin for uncleared swaps to be included in final prudential regulations, specifically that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received. 4. 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. 5. 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. 6. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, LCR, NRSRO, Derivatives and Swaps; reform proposals as they relate to securitization and capital markets generally; H.R. 4620, the Preserving Access to CRE Capital Act of 2016.

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

Bills named: H.R. 4620 (114th), H.R. 4166 (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. 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. HOA Superliens - Efforts in support of a 60 day notice to be given to noteholders if an HOA has been granted such superpriority status; also includes advocacy in support of regulators treating loans in private-label securitizations in the same fashion as FHFA treats Agency loans. 5. 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). 6. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.

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