lobbying_activities: 3141734
Data license: Public Domain (U.S. Government data) · Data source: Federal Register API & Regulations.gov API
This data as json
| id | filing_uuid | filing_type | registrant_name | registrant_id | client_name | filing_year | filing_period | issue_code | specific_issues | government_entities | income_amount | expense_amount | is_no_activity | is_termination | received_date |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 3141734 | 6dbaaa63-591b-436b-b320-689d8aa9676e | Q1 | STRUCTURED FINANCE ASSOCIATION | 401103239 | STRUCTURED FINANCE ASSOCIATION | 2024 | first_quarter | FIN | 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. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule. | Commodity Futures Trading Commission (CFTC),Consumer Financial Protection Bureau (CFPB),Federal Deposit Insurance Corporation (FDIC),Federal Reserve System,HOUSE OF REPRESENTATIVES,Labor, Dept of (DOL),Office of the Comptroller of the Currency (OCC),Securities & Exchange Commission (SEC),SENATE,Small Business Administration (SBA),Treasury, Dept of | 258149 | 0 | 0 | 2024-04-11T09:43:01-04:00 |