Market Structure & Dynamics

Regularly reviewing our market structure, processes and dynamics is a key component to achieving SFA’s mission of promoting a robust, liquid and healthy structured finance market as it grows and adapts to the consumers and businesses it supports.

It may surprise policymakers and regulators, as well as even some market participants, to know that it is currently very difficult – and sometimes impossible – for bondholders to communicate with the companies that issued the securities they own or for bondholders who own the same security to communicate with one another.

The current system is so unreliable that when evaluating potential solutions for the transition away from LIBOR, one of our financial markets’ most serious risk today, market participants view the option of soliciting bondholder consent for an amendment as largely unfeasible.

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“Market participants are keenly focused on and have rightfully questioned how – well into the digital age – the significant limitations of the current communication system remain.” – Kristi Leo, SFA, President

Market participants have rightfully questioned how – well into the digital age and long since record keeping transitioned from physical certificates to an electronic platform – the significant limitations of the current communication system remain. While there is certainly a complex chain of intermediaries that often separates the record-owner from the beneficial owner with only the final custodian retaining the record of the actual investor’s identity, today’s technology – including blockchain – provides viable solutions.

SFA is leading an effort within the structured finance market to identify the requirements for a robust and effective bondholder communication framework that could apply to all new bond issuance, if fully adopted.

Our Bondholder Communication Task Force has commenced a review of the current bondholder communication frameworks to identify operational, legal, economic and regulatory issues pertaining to those frameworks and drafted a specification document for an improved bondholder communication platform to address those issues. This project specification document will serve as the backbone for potential industry service providers to evaluate their ability to develop a platform meeting the industry’s needs at a cost point acceptable to the industry.

In February 2020, the Credit Ratings Subcommittee of the SEC’s Fixed Income Market Structure Advisory Committee (FIMSAC) held a meeting in which they discussed their recent discussion document on credit rating agency compensation models and perceived conflicts of interest. In response to the SEC’s request for market feedback, SFA is forming a Task Force to monitor the ongoing discussions at FIMSAC, respond to the FIMSAC’s request for industry input and help inform engagement should a formal policy recommendation be put before the SEC.

To join our task force, please contact [email protected].

“Strong governance is a key pillar of a sustainable securitization market, but we can’t fully have strong governance without a mechanism for transaction parties to communicate with each other in a timely fashion when the circumstances so require. I’m very optimistic that with the Structured Finance Association’s leadership and the commitment of industry participants we will finally be able to overcome what has been a persistent obstacle to better governance in our industry for many years.”

- Francisco Paez, MetLife Investments


Industry News

August 3, 2020

In a statement issued on Monday, August 3, the Federal Financial Institutions Examination Council (FFIEC) called for banking agencies to offer more loans and provide for additional loan modifications as the first-round of these programs comes to an end.

Industry News

July 31, 2020

Last Friday, July 31, Fitch Ratings announced that they would be lowering the U.S. government’s credit rating outlook from “stable” to “negative” but would be keeping the U.S.’s overall credit rating as AAA.

Industry News

July 28, 2020

During this week’s Federal Open Market Committee (FOMC) meeting, the Federal Reserve (the Fed) expressed doubts that the US economy would experience a V-shaped recovery in the near future. The doubt comes as numerous states are seeing increases in COVID-19 cases with some states rolling back the progress they made on reopening.

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Jen Earyes

Head of Policy

Jennifer Wolfe

Director, ABS and Investor Policy