Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

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. 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).

2. 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.

3. 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; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization.

4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working 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). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition.

5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions.

6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents.

7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent.

8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15.

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), Consumer Financial Protection Bureau (CFPB), Labor - Dept of (DOL), Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Commodity Futures Trading Commission (CFTC), Office of the Comptroller of the Currency (OCC), Small Business Administration (SBA)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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). Review and provide feedback on draft bipartisan bill to reform Fannie Mae and Freddie Mac.

2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a uniform mortgage backed security (UMBS) 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. Support of a free-market, competition-based approach to the GSE's use of alternative credit models.

5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.

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.

9. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II as it relates to RMBS issuance offerings.

10. Issues related to the Taxpayer Protection Act.

11. Credit Risk Transfer (CRT) - Issues related to the treatment of residential mortgage loans in forbearance under Section 4022 of the CARES Act as a delinquent loan under its fixed severity CRT bonds issued in 2013 and 2014 and concerns the about CRT programs of the GSEs as it relates to the FHFA's Enterprise Capital Rule re-proposal.

12. Enterprise Capital Rule Re-proposal - Issues related to the FHFA's re-proposed Enterprise Capital Rule and its potential impact on the broader system of housing services in the United States.

13. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes.

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), Securities & Exchange Commission (SEC), Ginnie Mae, Federal Reserve System

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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).

3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption.

4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Federal Reserve System, Office of the Comptroller of the Currency (OCC), Securities & Exchange Commission (SEC), Small Business Administration (SBA), Federal Accounting Standards Advisory Board (FASAB)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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

1. Tax Cuts and Jobs Act Implementation - Provisions potentially impacting securitization structures and markets, including treatment of housing finance, student loans, like-kind exchanges, and lease arrangements.

2. Outreach to IRS and Treasury regarding tax consequences stemming from LIBOR transition for securitizations and REMICs.

3. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Treasury - Dept of, Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes