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Structured Finance in the Courts (1)

Legal and Regulatory Issues

Legal advocacy is a key component of our mission to protect the structured finance market.

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Overview

When a case in the judicial system raises issues of foundational significance to the structured finance market, SFA will intervene to protect long-standing contractual doctrines, reasonable market expectations and a healthy, functioning market.

We partner with other trade groups on matters relates to topics of importance to the structured finance market. A few of the key legal cases we weighed in on are below.

NCSLT Resource Hub

SFA’s CFPB v. NCSLT Resources Hub houses previous SFA advocacy, helpful links and resources relating to the September 2017 lawsuit from the Consumer Financial Protection Bureau (CFPB) against the National Collegiate Student Loan Trusts (NCSLT). 

Explore the NCSLT Resource Hub

Publications & Resources

SFA Submits Comment Letter to SEC on Reforming Regulation S-K

April 1, 2026
On April 1, 2026, the Structured Finance Association (SFA) submitted a comment letter to the Securities and Exchange Commission (SEC) supporting the SEC’s review of Regulation S‑K, echoing Chairman Paul Atkins’s call to modernize disclosure requirements by eliminating immaterial information while preserving…
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SFA Submits Comment Letter to the IRS on Reporting Obligations for Auto Loan Securitizations

February 19, 2026
SFA submitted a letter to the IRS on the proposed regulations REG-113515-25 addressing reporting requirements tied to the new passenger vehicle loan interest deduction.
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SFA Responds to SEC’s Concept Release Pertaining to RMBS and ABS

November 26, 2025
On November 25, 2025, the Structured Finance Association (SFA) submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) in response to the SEC’s Concept Release regarding rules pertaining to residential mortgage-backed securities (RMBS) and asset-backed securities (ABS)….
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SFA Responds to IOSCO’s Consultation Report on Pre-Hedging

April 14, 2025
On February 21, SFA submitted a comment letter to the International Organization of Securities Commissions (“IOSCO”).  In the letter, SFA addresses questions presented in IOSCO’s consultation report including those around the proposed definition of pre-hedging; the use-cases of pre-hedging and…
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SFA Submits Comment Letter to the FDIC on Custodial Account Proposal

January 16, 2025
On January 16, 2025, the SFA submitted a letter to the FDIC on the Recordkeeping for Custodial Accounts proposal.
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SFA Prepares Educational Brief on Michigan HB 5354

October 24, 2024
SFA prepares an educational brief to the Michigan Department of Insurance and Financial Services on HB 5354.
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FAQs: Corporate Transparency Act Compliance

June 18, 2024
On June 13, 2024, the Structured Finance Association published a consensus document relating to FinCEN’s Beneficial Ownership Information Reporting Requirements
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SFA Conflict of Interest Resource Hub

May 28, 2025
The Securities and Exchange Commission (SEC) adopted Rule 192 on November 27, 2023, to prohibit conflicts of interest in certain securitization transactions. This rule applies to securitization participants involved in asset-backed securities (ABS) and aims to prevent conflicts of interest…
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SFA Submits Amicus Brief to the Supreme Court on NCSLT v. CFPB Case

September 23, 2024
On September 19th, the Structured Finance Association submitted an amicus brief to the U.S. Supreme Court urging the Court to review a Third Circuit decision that grants the Consumer Financial Protection Bureau enforcement authority over student loan securitization trusts.
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CFPB v. National Collegiate Student Loan Trusts – Litigation has the Potential to Destabilize the Securitization Market

August 20, 2024
The Consumer Financial Protection Bureau is seeking to hold innocent investors in Securitization Trusts responsible for the alleged wrongdoings of a third party.
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Contact

David Grey

David Dwyer

General Counsel, Policy and Regulatory Affairs

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