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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1776 I Street NW |
Address2 | Suite 501 |
City | Washington |
State | DC |
Zip Code | 20006 |
Country | USA |
3. Principal place of business (if different than line 2)
City | Washington |
State | DC |
Zip Code | 20006 |
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 | 2018 |
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: Leslie Sack |
Date | 7/12/2018 5:07:36 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
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the risk retention compliance requirements for CLOs.
2. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs).
3. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans.
4. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; H.R. 10 (The Financial CHOICE Act), specifically risk retention provisions, Volcker Rule (discussed SFIG recommended changes with staff at SEC, Federal Reserve Board, and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; S.2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act), specifically provisions potentially related to securitization.
5. S.1642/H.R.3299 (Protecting Consumers' Access to Credit Act of 2017) - Issues concerning the effect on the secondary loan market and, by extension, securitizations.
6. Working with SFIG members and the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFIG was selected to co-chair the ARRCs Securitization Working Group which is meeting regularly with the goal of producing concrete recommendations on how best to effect the transition.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC)
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 |
Leslie |
Sack |
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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 - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT).
2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs
3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives).
4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models.
6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation.
7. ATR/QM - General issues concerning loan origination and GSE underwriting standards.
8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice, including lobbying and advocacy around proposed legislative fixes to the FCA.
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, Consumer Financial Protection Bureau (CFPB), Housing & Urban Development - Dept of (HUD)
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 |
Leslie |
Sack |
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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
1. General issues concerning international efforts to establish "high-quality securitization" criteria.
2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of
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 |
Leslie |
Sack |
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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 TAX
16. Specific lobbying issues
H.R.1 (Tax Cuts and Jobs Act) - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
Leslie |
Sack |
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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 |