SFA on the Issues

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

SFA Supports the Fed LIBOR Proposal with Some Remaining Clarifications Needed

SFA submitted a letter to the Board of Governors of the Federal Reserve System (Fed) in response to the Fed’s proposed regulation to implement the Adjustable Interest Rate (LIBOR) Act.

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SFA Sends Letter to GSEs on Social Index

SFA sends letter to Fannie Mae and Freddie Mac on their joint Social Index for single-family MBS commending them for their work while noting the areas where investors seek additional granularity and transparency.

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SFA Submits Brief to Third Circuit Appellate in CFPB v. NCSLT Case

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.

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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.

SFA Responds to SEC Private Funds Proposal Impacting CLOs

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.

SFA Response to the Securities and Exchange Commission’s Request for Comment on Climate Change Disclosures

June 11, 2021

SFA’s response to the Securities and Exchange Commission on the Request for Comment on Climate Change Disclosure details the work that SFA and the ESG Task Force have undertaken, draws distinctions between the securitization market and other markets, and suggests a path forward for climate disclosures.

What do you see as our Biggest Challenge

October 4, 2021

Listen to our panelsit discuss what the bigges challenges to our economic recovery post pandemic are.

SFA Responds to FIMSAC Recommendations to Mitigate Conflicts of Interest in Credit Ratings

December 22, 2020

SFA’s response to the Fixed Income Market Structure Advisory Committee (FIMSAC) recommendation regarding ways to mitigate conflicts on interest in credit ratings focused on 1) enhanced issuer disclosure, 2) increased NRSRO disclosure, 3) bondholder ratification of issuer-selected NRSROs, and 4) our members’ general comments around potential conflicts of interest.

SFA Joint Trade Amicus on LIBOR Transition

December 15, 2020

SFA jointly filed an amicus brief with the Chamber of Commerce, SIFMA, ISDA, BPI, and LSTA, in the case of McCarthy v. Intercontinental Exchange, Inc., in the Northern District of California. The case has significant implications for the LIBOR transition and global financial markets. The plaintiffs in McCarthy v. Intercontinental Exchange, Inc. are requesting to bring the publication of the U.S. LIBOR benchmark rate to an immediate halt, threatening to disrupt financial transactions all over the world and undermine years of planning for an orderly transition from LIBOR.

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COVID-19: Supporting Consumers & Businesses

Capital & Other Bank Regulations

Disclosure & Reporting

ESG Disclosure Initiative

Global Initiatives

Housing Finance

LIBOR Transition

Market Structure & Dynamics

Research Corner

Structured Finance in the Courts

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