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.

November 18, 2021

On October 18th FHFA Acting Director Sandra L. Thompson announced that the temporary use of desktop appraisals, adopted during the Covid-19 crisis, would become an established option. The FHFA is also considering the risks and benefits of the increased use of appraisal waivers, up more than 6.9 times the average level in 2018, as it continues to modernize the appraisal process. Additionally, the FHFA requested industry input on the risks posed by increased use of waivers and automated valuation models (AVMs) and comments on how expanded AVM use could impact racial bias in property valuations. Modernization of the appraisal process is included in the 2022 FHFA Scorecard, which holds the Enterprises "accountable for fulfilling their core mission requirements by promoting sustainable and equitable access to affordable housing and operating in a safe and sound manner."

November 15, 2021

The goal of the QM VSH Scope of Review is to create a uniform best practice testing standard to be utilized across TPR firms. The primary focus of this initial version of SFA’s TPR Scope of Review for QM VSH is to document the best practice approaches used by clients utilizing a TPR firm to perform due diligence on General QM loans under the new rule effective March 1, 2021.. As appropriate, SFA and its members will continue to work with the CFPB toward the goal of receiving formal regulatory guidance for the benefit of the consumer, primary, and secondary mortgage markets. To that end, there may be shifts in the requirements should there be future CFPB rulemakings or formal guidance, or market developments.

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.

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.

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 Task Force

Global Initiatives

Housing Finance

LIBOR Transition

Market Structure & Dynamics

Research Corner

Structured Finance in the Courts

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