SFA on the Issues

Educating legislators and regulators on policy matters is essential to the structured finance industry.

As an organization whose members have incredibly diverse interests and varied perspectives, the Structured Finance Association engages in advocacy, policy and research regarding issues impacting the safe and sound functioning of the entire securitization and structured finance markets.

We see our role as that of a bridge, linking the policymaking and securitization communities to ensure that an informed, two-way dialogue allows for robust discussion and optimal policy outcomes.

January 30, 2024

On January 26, 2024, the Structured Finance Association (SFA) submitted a comment letter to the National Association of Insurance Commissioners (NAIC) in response to their exposure draft titled Amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (the “P&P Manual”) Authorizing the Procedures for the SVO’s Discretion Over NAIC Designations Assigned Through the Filing Exemption Process.  

January 8, 2023

In August of 2022, Fannie Mae proposed a methodology to score their single-family MBS pools using Social data and metrics. In October 2022, both Fannie Mae and Freddie Mac announced that they would align their disclosure practices around the Social Index Score. In response to the GSEs request for comments, SFA sent a letter to both GSEs on January 5, 2023 SFA investor feedback on the Social Index, commending the GSEs for working on enhanced Social disclosures, while also providing the GSEs with the additional type of transparent, granular reporting metrics that provide the bulk of the utility that they rely on to make investing decisions. More work is still needed to provide investors the needed disclosure for ESG Social investing, and SFA is engaging with issuers and investors to identify what those metrics are while, critically, ensuring that the privacy of mortgage borrowers is maintained.

October 14, 2022

SFA recently submitted an amicus brief to the Third Circuit Appellate in the CFPB v NCSLT case, supporting trusts arguments that passive securitization trusts are not under CFPB Enforcement Authority.

May 11, 2022

On April 25, SFA recommended important changes to the SEC’s proposed amendments to the Investment Advisers Act in order to tailor the rule’s application to the unique aspects of the CLO market versus hedge funds and private equity funds.

October 4, 2021

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Structured Finance in the Courts

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