The goal of the QM VSH Scope of Review is to create a uniform best practice testing standard to be utilized across TPR firms. The primary focus of this initial version of SFA’s TPR Scope of Review for QM VSH is to document the best practice approaches used by clients utilizing a TPR firm to perform due diligence on General QM loans under the new rule effective March 1, 2021.. 适当的, SFA and its members will continue to work with the CFPB toward the goal of receiving formal regulatory guidance for the benefit of the consumer, primary, and secondary mortgage markets. 为实现这一目标, there may be shifts in the requirements should there be future CFPB rulemakings or formal guidance, or market developments.

SFA’s response to the Fixed Income 市场结构 Advisory Committee (FIMSAC) recommendation regarding ways to mitigate conflicts on interest in credit ratings focused on 1) enhanced issuer disclosure, 2) increased NRSRO disclosure, 3) bondholder ratification of issuer-selected NRSROs, and 4) our members’ general comments around potential conflicts of interest.

SFA jointly filed an amicus brief with the Chamber of Commerce, SIFMA, ISDA, BPI, 和LSTA, in the case of McCarthy v. Intercontinental Exchange, Inc., in the Northern District of California. The case has significant implications for the LIBOR transition and global financial markets. The plaintiffs in McCarthy v. Intercontinental Exchange, Inc. are requesting to bring the publication of the U.S. LIBOR benchmark rate to an immediate halt, threatening to disrupt financial transactions all over the world and undermine years of planning for an orderly transition from LIBOR.