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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1775 Pennsylvania Avenue, NW |
Address2 | Suite 625 |
City | Washington |
State | DC |
Zip Code | 20006-4758 |
Country | USA |
3. Principal place of business (if different than line 2)
City | Washington |
State | DC |
Zip Code | 20006-4758 |
Country | USA |
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5. Senate ID# 401103239-12
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6. House ID# 425350000
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TYPE OF REPORT | 8. Year | 2015 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Michael P. Flood, Jr. |
Date | 10/19/2015 2:57:57 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
During the second quarter 2015, SFIG advocated on the following issues:
1. CLO's - for changes to the compliance date for collateralized loan obligations to the Volcker rule through Title VIII of the Promoting Job Creation and Reducing Small Business Burdens Act (Act) of 2015. SFIG is also advocating for a qualified CLO retention regime as an alternative to the final risk-retention rules.
2. Basel Capital and Liquidity Treatment for asset-backed securities - SFIG lobbied for appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules.
3. SFIG is advocating for an exemption from posting margin for uncleared swaps to be included in the final prudential regulations. Captive finance companies have already received this exemption through a no-action letter from the CFTC. SFIG believes that non-captive finance companies and financial institutions should receive the same exemption that captive finance companies received.
4. Marketplace Lending - SFIG advocated for Congress and regulators to review the current rules in place for securitization as it relates to marketplace lending prior to making and new regulatory or legislative decisions for this new form of funding.
5. Regulation AB II - SFIG submitted a comment letter to the SEC on outstanding issues remaining in the final Regulation AB II rule. SFIG also discussed Regulation AB II with Congress.
5. General Dodd-Frank Reform Efforts. SFIG also discussed upcoming and final rules with both the regulators as well as Congress, including risk retention, regulation AB II, LCR, NRSRO, HQS, Derivatives and Swaps
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, White House Office, Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Treasury - Dept of, Securities & Exchange Commission (SEC), Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Michael |
Flood |
Jr. |
Office of Management and Budget Program Examiner from 02-2009 to 06-2010 |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HOU
16. Specific lobbying issues
1. GSE Reform - SFIG advocated for inclusion of a federal guaranty, preservation of the TBA market, inclusion of private capital in the first loss position. SFIG wants to ensure that whole loans, a government guarantee, and private-label securitization markets are liquid and well regulated in any new housing finance system.
2. General Housing Finance Issues - SFIG has advocated for increased industry participation in the FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP). SFIG advocated with the Congress and the FHFA through meetings and response letters, and with Congress through SFIG's support for a title in Senator Shelby's FRIA bill which calls for increased risk-sharing and industry participation. As of July, SFIG is now a participant on the Common Securitization Solutions' Industry Advisory Group for the SS/CSP. While the Industry Advisory Group itself is non-policy focused, SFIG will continue to advocate with the FHFA and Congress for increased industry participation and project transparency.
3. Mortgage REITs - SFIG is advocating for mortgage REITs to be allowed to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac.
4. HOA Superliens - Some states allow HOA's superpriority status - ahead of the noteholder - in a foreclosure proceeding if dues or homeowners fees are owed. An HOA may be able to foreclose for such late fees ahead of the noteholder. SFIG is advocating for 60 days notice to be given to noteholders if an HOA has been granted such superpriority status. SFIG is also advocating that regulators treat loans in private-label securitizations in the same fashion as FHFA is treating Agency loans when it comes to such HOA Superliens.
5. Eminent Domain - SFIG advocated for the continued ban on government-guaranteed programs to purchase any loan where eminent domain has been enacted. This language has been included in appropriations bills for the past two fiscal years.
6. PLS - SFIG advocated for industry agreed-upon solutions arrived at in its RMBS 3.0 project to be included in as part of any new structure for the return of private-label mortgage-backed securities, including Treasury's project to bring back the PLS market.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Housing Finance Agency (FHFA), Treasury - Dept of, White House Office, Securities & Exchange Commission (SEC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Michael |
Flood |
Jr. |
Office of Management and Budget Program Examiner from 02-2009 to 06-2010 |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BAN
16. Specific lobbying issues
SFIG advocated lawmakers and regulators regarding international efforts to establish "high-quality securitization" criteria.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Office of the Comptroller of the Currency (OCC), White House Office, Treasury - Dept of, Federal Housing Finance Agency (FHFA), Securities & Exchange Commission (SEC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Michael |
Flood |
Jr. |
Office of Management and Budget Program Examiner from 02-2009 to 06/2010 |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CDT
16. Specific lobbying issues
Advocated on SPV's and swaps
17. House(s) of Congress and Federal agencies Check if None
Commodity Futures Trading Commission (CFTC), U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Securities & Exchange Commission (SEC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Michael |
Flood |
Jr. |
Office of Management and Budget Program Examiner from 02-2009 to 06/2010 |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 3 | 5 |
2 | 4 | 6 |